Podcast - Discussing a DOJ Lawsuit Under the Civil-Fraud Initiative
Navigating Regulatory Waters: Recent Enforcement Actions in BaaS — Payments Pros – The Payments Law Podcast
The Presumption of Innocence Podcast: Episode 47 - Fireside Chat With Bill Baroni and Jesse Eisinger
Episode 340: DOJ Updates Evaluation of Corporate Compliance Programs
Public-Private Partnerships to Stem Corruption
Episode 339: Four Sanctions Cases Everyone Should Know
Enhancing Compliance: The Power of Independent Monitorships in Consumer Protection — Regulatory Oversight Podcast
Episode 338 -- Deep Dive into the Deere SEC FCPA Case
The Legal Tightrope: Surviving Parallel Investigations
Navigating Government Contracts: Diana Shaw on Oversight and Whistleblower Protections
The Presumption of Innocence Podcast: Episode 45 - The Grit, Grace and Gift of Second Chances
The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and Restrictions
False Claims Act Insights - Are All Healthcare “Kickbacks” Subject to FCA Liability?
Episode 333 -- The Boeing Proposed Plea Agreement
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
False Claims Act Insights - Assessing the Fallout from a Thermonuclear FCA Verdict
FCPA Survival Guide - Step 8 - Investing in Compliance
Exploring the AI and Crypto Intersection
The Justice Insiders Podcast: Jarkesy’s Implications for the Administrative State
The Presumption of Innocence Podcast: Episode 41 - The Dynamics of Decision-Making: Psychology and the Criminal Justice System
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
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
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
Following an 8 week trial, a federal jury in Brooklyn has convicted Javier Aguilar on charges relating to the former Vitol trader’s violations of the Foreign Corrupt Practices Act. He faces up to 30 years in prison. Aguilar...more
Each FCPA case provides valuable lessons in the mechanics of bribery schemes and the common techniques used by violators to secure funds and make illegal payments to foreign government officials. Criminal violators often act...more
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
The SEC announced another FCPA settlement in 2022. FCPA enforcement, in general, is picking up. Tenaris, a global supplier of steel pipes and related services for the energy industry, agreed to pay the SEC $78 million to...more
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
This week I have been considering the guilty pleas of the former Unaoil Chief Executive Officer (CEO), Cyrus Ahsani, and former Chief Operations Officer (COO), Saman Ahsani, as was laid out in their Information. Most...more
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
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 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
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
On June 12, 2019, the World Bank announced that China-based Dongfang Electronics Co. Ltd. (“Dongfang”) would be debarred for fifteen (15) months for fraudulently bidding on a $60 million electrical expansion project in...more
ANTICORRUPTION DEVELOPMENTS - DOJ Unseals Indictment of Two More Individuals Connected With PDVSA Corruption Scheme - On February 26, 2019, the U.S. Department of Justice (DOJ) announced the unsealing of an indictment...more
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 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
In a December 2018 enforcement settlement, the SEC and Brazil’s Centrais Elétricas Brasileiras S.A. (“Eletrobras”) agreed to violating books and records and internal accounting controls requirements and paid a $2.5 million...more
Last year (on Monday) I began a two-part blog series on the final two Foreign Corrupt Practices Act (FCPA) of 2018. On Monday, we considered the Polycom, Inc. FCPA enforcement action and today we consider the enforcement...more
• Four years ago, Brazilian authorities began Operation Car Wash, a wide-ranging and still ongoing corruption and money laundering investigation that has spanned 11 countries. • The fallout continues with a recent U.S....more
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
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
ANTICORRUPTION DEVELOPMENTS - Petrobras Settles with U.S. Authorities Over Alleged FCPA Violations - On September 27, 2018, the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC)...more
The Justice Department added to its roster of criminal FCPA defendants. Going back to 2017, it is clear that the Yates Memorandum requirements have resulted in an increase in criminal FCPA prosecutions....more