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The Volkov Law Group

Trafigura’s Bribery Scheme: Clandestine Meetings, 3rd Parties and Shell Companies (Part II of III)

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Trafigura’s bribery scheme resembles the same schemes implemented by its significant competitors — Vitol, Glencore, Gunvor.  At the core of the conduct, Petrobras and Brazilian government officials collected bribes in...more

Thomas Fox - Compliance Evangelist

The Trafigura FCPA Enforcement Action – Part 4 – Lessons Learned

We conclude our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international commodity trading company with its primary operations in...more

Thomas Fox - Compliance Evangelist

The Trafigura FCPA Enforcement Action-Part 3-The Penalty

We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm trading firm G Trafigura Beheer B.V. (Trafigura), an international commodity trading company with its primary...more

Thomas Fox - Compliance Evangelist

The Gunvor FCPA Enforcement Action: Part 2 – The Bribery Schemes

We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm Gunvor S.A. The enforcement action came in with a $661 million penalty against the company, which has pleaded...more

Thomas Fox - Compliance Evangelist

The Gunvor FCPA Enforcement Action: Part 1-Introduction

In March 2024, the Department of Justice (DOJ) announced the resolution of a FCPA enforcement action involving the Swiss trading firm Gunvor S.A. The enforcement action comes in with a $661 million penalty against the...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 2 – How to Hire Corrupt Agents

Last week, Albemarle Corporation (Albemarle), agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more

The Volkov Law Group

Lessons Learned from the Albemarle FCPA Enforcement Action: Mind Your Third Parties (Part III of III)

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The Albemarle FCPA enforcement action was announced at a good time.  This year has been a slow year for DOJ’s FCPA enforcement program, although there are several months before the end of the year. The SEC, on the other hand,...more

The Volkov Law Group

Albemarle’s Reliance on Third-Parties to Execute Bribery Schemes (Part II of III)

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Albemarle’s bribery schemes look and sound like text-book examples of third-party agents being paid high commissions as a way to funnel bribery payments to foreign officials at state-owned oil refineries.  However, as usual,...more

The Volkov Law Group

Albemarle Settles DOJ and SEC FCPA Cases for $218 Million (Part I of III)

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Albemarle Corporation (Albemarle), a specialty chemicals manufacturing company located in Charlotte, North Carolina, agreed to pay more than $218 million to settle FCPA investigations with DOJ and the SEC stemming from...more

The Volkov Law Group

DOJ Charges Two Oil and Gas Traders with FCPA Bribery Scheme Involving Petrobras

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In its first enforcement action of 2023, the Justice Department charged a Connecticut man and a foreign national with FCPA bribery and money laundering charges stemming from a bribery scheme to secure contracts with Petrobras...more

The Volkov Law Group

DOJ Charges Two Companies and A Dozen Individuals for Export Control and Sanctions Violations to Aid Russian Military

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The Justice Department promised aggressive enforcement of export controls and sanctions against Russia.  To that end, DOJ initiated the KleptoCapture task force to focus law enforcement investigations of export violators. ...more

The Volkov Law Group

Glencore’s Commodity Trading Fraud Scheme (Part IV of V)

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Glencore’s settlement with DOJ and the CFTC revealed a plethora of manipulative, deceptive and corrupt conduct, which spanned from at least 2007 to 2018 and occurred in the United States and global oil markets, including...more

The Volkov Law Group

DOJ and SEC Announce First Corporate FCPA Settlement for 2021: Amec Foster Wheeler, a Wood Group Subsidiary, Agrees to Pay over...

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The Justice Department and the Securities Exchange Commission are back in business.  The first corporate FCPA enforcement action in 2021 came after a six-month hiatus in 2021.  While many commentators sought to read the...more

Orrick, Herrington & Sutcliffe LLP

For the First Time, the CFTC Uses its Powers to Combat Foreign Corruption

In a landmark action on December 3, 2020, the Commodity Futures Trading Commission (“CFTC”) announced resolution of its first enforcement action involving foreign corruption by issuing an order and settling charges against...more

The Volkov Law Group

Vitol Pays $163.7 Million to Settle FCPA Case (Part I of III)

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The Justice Department continues to produce FCPA resolutions in a record year for enforcement.  The latest, and perhaps the beginning of several end-of-year and end of the Trump Administration resolutions, is DOJ’s settlement...more

The Volkov Law Group

Sargeant Marine Pleads Guilty to FCPA Charges and Agrees to Pay $16.6 Million

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The Justice Department announced a guilty plea to FCPA charges by Sargeant Marine, Inc., a privately-owned company, based in Boca Raton, Florida.  Sargeant Marine, an asphalt company, plead guilty to one count of conspiracy...more

Hogan Lovells

ADG Insights: Bribery and corruption continues to be a risk for ADG companies - February 2020

Hogan Lovells on

The anti-corruption and bribery enforcement landscape is constantly evolving. Companies operating in the Aerospace, Defense, and Government Services (ADG) industry sector must therefore vigilantly track developments in this...more

A&O Shearman

Korean Engineering Company Fined $75 Million Over Alleged Foreign Bribery Scheme In Brazil

A&O Shearman on

On November 22, 2019, the U.S. Department of Justice (“DOJ”) announced that it had entered into a three-year deferred prosecution agreement (“DPA”) with a Korean engineering company (“SHI”) to settle allegations of Foreign...more

Thomas Fox - Compliance Evangelist

Lessons Learned from the Samsung FCPA Enforcement Action

Last week, another Foreign Corrupt Practices Act (FCPA) case was resolved. It involved Samsung Heavy Industries Company Limited (SHI), a South Korea-based engineering company that provides shipbuilding, offshore platform...more

The Volkov Law Group

Samsung Agrees to Pay $75 Million to Resolve FCPA Violations (Part I of II)

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Samsung Heavy Industries agreed with the Justice Department to pay $75 million to settle FCPA charges. Under a three-year deferred prosecution agreement (DPA), Samsung agreed to filing of a criminal information in the Eastern...more

Thomas Fox - Compliance Evangelist

Ex-Braskem CEO Indicted on FCPA, AML and Books and Records Charges

Yesterday, the Department of Justice (DOJ) announced three charges against Jose Carlos Grubisich, the former Chief Executive Officer (CEO) of Braskem S.A. (Braskem), a publicly traded Brazilian petrochemical company, for his...more

Thomas Fox - Compliance Evangelist

The Ahsani’s Information – The Fraudulently Obtained Certifications

This week I am mining the guilty pleas of the former Unaoil Chief Executive Officer (CEO), Cyrus Ahsani, and former Chief Operations Officer (COO), Saman Ahsani, for what they might mean for Foreign Corrupt Practices Act...more

Thomas Fox - Compliance Evangelist

The Ahsanis’ Information – Are You On The List?

Yesterday, I began a consideration of the guilty pleas of the former Unaoil Chief Executive Officer (CEO), Cyrus Ahsani, and former Chief Operations Officer (COO), Saman Ahsani, and what they might mean for Foreign Corrupt...more

The Volkov Law Group

Justice Department Unseals Unaoil Executives’ FCPA Guilty Pleas

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The Justice Department announced that three Unaoil executives entered FCPA guilty pleas last year.  The three executives cooperated with law enforcement in the investigation and prosecution of other companies and...more

Thomas Fox - Compliance Evangelist

The Panalpina Settlement Day Record May Finally Be Broken: The Unaoil Execs Guilty Pleas

Nine years ago today, on November 4, 2010, was Panalpina Settlement Day which made history for the single largest number of companies to simultaneously settle Foreign Corrupt Practices Act (FCPA)-related violations. It was...more

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