DE Under 3: Letter Calling for the Suspension & Debarment of “Corporate Criminals” from Obtaining Federal Contracts
Episode 26: Should We Call the Debarment Official or Wait?
Suspension and Debarment: Part 5- Remedies and Compliance in Suspension and Debarment
Suspension and Debarment: Part 3- The convergence between the FCPA and suspension and debarment
Suspension and Debarment
Polsinelli Podcast - The Climate for I9 Audits in 2015
While much attention is given to compliance with applicable laws, such as the U.S. Foreign Corrupt Practices Act of 1977, many companies working on projects sponsored by Multi-Lateral Development Banks (“MDBs” or “MDB”)...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
Ignoring integrity risks in emerging markets when receiving financing from the World Bank Group (WBG) is about to become much riskier, as the WBG Sanctions System Annual Report for Fiscal Year 2022 (FY22) indicates. The...more
In October, the World Bank Group (WBG) published its third Sanctions System Annual Report for Fiscal Year 2020 (FY20), which covers the period from 1 July 2019 to 30 June 2020. The report provides a detailed look at the...more
Pay attention to sanctions and debarment risks amid new COVID-19 financing opportunities. In recent weeks, the World Bank, the African Development Bank (AfDB) and other multilateral development banks (MDBs) have greenlit...more
On October 10, 2019, the World Bank Group issued its second joint Sanctions System Annual Report for Fiscal Year 2019 (“Report”), which addresses the World Bank’s efforts to investigate and adjudicate allegations of...more
Recent debarments of contractors by the World Bank underscore the need for entities working under multilateral development bank (“MDB”) contracts to implement effective anti-corruption project finance mitigation strategies...more
ANTICORRUPTION DEVELOPMENTS - Telecommunications Company Fined $12 Million for FCPA Violations - On August 29, 2019, The Securities and Exchange Commission (SEC) instituted ceaseand-desist proceedings against...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
• The World Bank aggressively pursues sanctions against entities and individuals for misconduct in connection with Bank-funded projects • Sanctions can lead to cross-debarment by other multilateral development banks and...more
ANTICORRUPTION DEVELOPMENTS - $34 Million SEC Settlement for Legg Mason - On August 27, 2018, the Securities and Exchange Commission (SEC) announced that Legg Mason Inc. will pay more than $34 million to settle an...more
ANTICORRUPTION DEVELOPMENTS - DOJ Extends FCPA Corporate Enforcement Policy to Misconduct in Mergers and Acquisitions - On July 25, 2018, in a speech to the Ninth Global Forum on Anti-Corruption Compliance in High Risk...more
ANTICORRUPTION DEVELOPMENTS – Canadian Mining Company Settles with SEC over FCPA Charges – On March 26, Kinross Gold Corporation settled with the Securities and Exchange Commission (SEC) over its alleged failure to...more
• Companies that operate globally face substantial risks associated with activities funded by multilateral development banks (MDBs). • Several recent debarment actions by the World Bank highlight those risks. • To...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
ANTICORRUPTION DEVELOPMENTS – Keppel Offshore Reaches Deal with DOJ and Guilty Plea by Counsel Unsealed – On December 22, 2017, Keppel Offshore & Marine Ltd. (KOM), a Singapore based company that operates shipyards and...more
ANTICORRUPTION DEVELOPMENTS – Keppel Offshore Reaches Deal with DOJ and Guilty Plea by Counsel Unsealed – On December 22, 2017, Keppel Offshore & Marine Ltd. (KOM), a Singapore based company that operates shipyards...more
ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more