FCPA Survival Guide - Step 8 - Investing in Compliance
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
Compliance Tip of the Day – Compliance Lessons from the Albemarle FCPA Enforcement Action
FCPA Survival Guide: Step 1 - Self-Disclosure
All Things Investigations: Compliance Lessons from Gunvor and Trafigura Enforcement Actions
Corruption, Crime & Compliance: Deep Dive into The Trafigura FCPA Settlement
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
Compliance into The Weeds: Trafigura FCPA Enforcement Action
Corruption, Crime & Compliance: Deep Dive into The Gunvor FCPA Settlement
Episode 314 -- A Deep Dive into Gunvor's FCPA Settlement
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 311 -- Tom Fox on FCPA Enforcement: Self Disclosure and Recidivism
Episode 307 -- Sanctions Enforcement Review and Predictions for 2024
Episode 305 -- Deep Dive into SAP FCPA Settlement
Compliance Into The Weeds: The SAP Foreign Corrupt Practices Act Enforcement Action
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
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
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
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
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 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
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
• 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
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
ANTICORRUPTION DEVELOPMENTS – U.S. Agencies Decline to Prosecute Teradata for Alleged FCPA Violations – On February 26, 2018, Teradata Corporation, an Ohio-based enterprise software database management company,...more
As forecasted in a blog post last summer, the United States Department of Justice (“DOJ”) has again used the money laundering statute to accomplish the otherwise elusive goal of prosecuting foreign officials who allegedly...more
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