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Energy Sector Department of Justice (DOJ) Compliance

Morgan Lewis

Energy Industry in the Government’s FCPA Crosshairs: Recent Enforcement and Policy Developments - Empowered

Morgan Lewis on

The energy industry in general and the oil and gas industry in particular has been the target of at least 50 Foreign Corrupt Practices Act (FCPA) prosecutions over the years—more than any other industry. Most of the cases...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

The Volkov Law Group

Goldman Sachs Official Indicted Over Ghana Bribery Scheme (Part I of II)

The Volkov Law Group on

Talk about a reminder of the past, Asante Berko, a former Executive Director in Goldman Sachs, recently was arrested in London on criminal FCPA charges arising from his involvement in a bribery scheme in Ghana....more

K2 Integrity

Sanctions Against Russia: The Week in Review - April 2022 - 4

K2 Integrity on

The Week in Review delivers the impact and analysis for the public, private, and non-profit sectors from our regular reporting of the evolving global sanctions campaign against Russia. This week, we reviewed the recent...more

Womble Bond Dickinson

Biden Administration Prioritizes Corporate Criminal Enforcement

Womble Bond Dickinson on

Takeaways: ..In recent remarks, top DOJ officials stated that DOJ will “surge resources” and “redouble efforts” for corporate enforcement. ..Areas of particular concern include Foreign Corrupt Practices Act,...more

Thomas Fox - Compliance Evangelist

Another Guilty Verdict in a FCPA Trial – Mark Lambert

Last Friday, the Department of Justice (DOJ) secured another trial court conviction in a Foreign Corrupt Practices Act (FCPA) prosecution involving an individual. Following on the heels of the Hoskins guilty verdict, it...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

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

King & Spalding

Energy Newsletter - June 2019

King & Spalding on

Corporate Compliance Programs: DOJ Issues Updated Guidance: Ten Takeaways for In-House Legal and Compliance Leaders - On April 30, 2019, Assistant Attorney General Brian Benczkowski unveiled an update to the Department of...more

WilmerHale

Foreign Corrupt Practices Act Enforcement in the Energy Sector

WilmerHale on

This is the sixth issue of WilmerHale’s 10-in-10 Hot Topics in Energy Series. Over the course of 10 weeks, our attorneys will share insights on current and emerging issues affecting the US energy sector....more

The Volkov Law Group

DOJ Sweeps Up Two More Defendants in PDVSA Criminal Investigation

The Volkov Law Group on

The Justice Department’s sprawling and successful prosecution of bribery and money laundering surrounding PDVSA, Venezuela’s state-owned energy company, shows no signs of letting up. ...more

Thomas Fox - Compliance Evangelist

The NPA; The Petrobras FCPA Enforcement Action: Part III

This blog post concludes my multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. Today we consider the stunning result achieved by Petrobras –...more

The Volkov Law Group

Petrobas Closes Out “Massive” Corruption Investigations and Litigation

The Volkov Law Group on

When it comes to a poster-child for corrupt organizations, there is very little competition that can eclipse Petrobas, the Brazilian state-owned oil and gas company. ...more

The Volkov Law Group

DOJ Settles Follow-On FCPA Case: Transport Logistics Pays $2 Million Penalty

The Volkov Law Group on

Last week, the Justice Department announced its first FCPA enforcement action in 2018 – a follow-on settlement from prior FCPA enforcement actions centering on a bribery scheme involving a Russian government official from a...more

The Volkov Law Group

Justice Department Closes Out 2017 with 2 FCPA Actions: Keppel Offshore and Marine and Embraer Individual

The Volkov Law Group on

The Department of Justice finished 2017 with two significant FCPA enforcement actions, and fittingly, one was a corporate settlement and another was an individual criminal guilty plea. The Justice Department’s final FCPA...more

The Volkov Law Group

DOJ Continues Run on Individual FCPA Criminal Prosecutions

The Volkov Law Group on

The Department of Justice announced criminal FCPA charges against two individuals in connection with bribery payments to foreign officials in Chad and Uganda. The Justice Department’s announcement occurred on the heels of...more

Thomas Fox - Compliance Evangelist

Rolls Royce in America – Four Guilty Pleas and an Indictment

For those who might have wondered if the Sessions Justice Department (DOJ) was going to enforce the Foreign Corrupt Practices Act (FCPA), that question seems to have been answered in the affirmative. In September, the DOJ and...more

The Volkov Law Group

Justice Department Resolves Two Cases Under FCPA Pilot Program

The Volkov Law Group on

The Justice Department recently resolved two separate FCPA investigations under its Pilot Program. To be sure, DOJ’s resolution of these two matters reinforces the real and tangible benefits of its Pilot Program....more

Thomas Fox - Compliance Evangelist

Linde in the Republic of Georgia: A Declination and Lessons Learned

Yesterday the FCPA Professor reported the Department of Justice (DOJ) had issued a Declination to Linde North American Inc. and Linde Gas North America LLC (collectively “Linde”). This is the first Declination issued by the...more

Morrison & Foerster LLP

Top Ten International Anti-Corruption Developments for January 2017

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Thomas Fox - Compliance Evangelist

Doing Compliance in an Economic Downturn

The city of Houston has seen a multi-year economic downturn from the drop in the price of oil. Every company in the energy space has been required to dramatically cut its work force, including unfortunately, it compliance...more

The Volkov Law Group

Serious Fraud Office Makes Big Splash with UK Bribery Act Resolution with Rolls Royce

The Volkov Law Group on

After years of fits and starts, and promises and disappointments, the Serious Fraud Office and the UK Bribery Act made its initial splash on the anti-corruption enforcement landscape. Since 2011, companies have been...more

The Volkov Law Group

Double Play, Double Declinations: DOJ Pushes FCPA Pilot Program Benefits

The Volkov Law Group on

DOJ’s FCPA Pilot Program was panned when it was announced in April 2016. Critics contended that the incentive for voluntary disclosure of FCPA violations to DOJ was inadequate....more

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