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White Collar Crimes Enforcement Actions Oil & Gas

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 Trafigura 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 G Trafigura Beheer B.V. (Trafigura), an international commodity trading company with its primary operations in...more

The Volkov Law Group

Gunvor’s Bribery Schemes — Third-Parties, Shell Companies and Evasion of Controls (Part II of III)

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Gunvor’s bribery scheme is not very surprising nor ingenious.  After all, a number of energy trading companies have been prosecuted for bribery over the years, including Glencore, Vitol, Freepoint.  Numerous individuals have...more

Thomas Fox - Compliance Evangelist

The Gunvor FCPA Enforcement Action: Part 3-the Discounted Fine

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 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

Ex-Vitol Oil & Gas Trader Convicted of Bribing Foreign Officials

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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

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

Frank’s International Pays SEC $8 Million to Resolve FCPA Violations In Angola

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Franks International (“Frank’s”) settled FCPA charges with the SEC for $8 million stemming from operations in Angola during the period 2008 to 2014.  The Justice Department declined to prosecute Frank’s for the same events....more

Cadwalader, Wickersham & Taft LLP

“Car Wash” is no more but enforcement continues outside of Brazil’s borders

Overview - A recent spate of cases on both sides of the Atlantic in 2023 show that criminal enforcement and asset recovery proceedings stemming from the iconic Brazilian anti-corruption investigation, Operation “Car Wash”...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

Lessons Learned: Foster Wheeler FCPA Settlement Underscores Danger of Third-Party Risks (Part III of III)

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We all know and hear about third-party risks – over and over again. Despite this recurring theme, organizations continue to pay the price for failing to address third-party issues.  It does not take a rocket scientist to...more

The Volkov Law Group

Foster Wheeler FCPA Action: Dancing with the Devil – Risky Third Parties (Part II of III)

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FCPA settlement actions often underscore specific compliance risks for legal and compliance professionals. If there ever was a case where third-party risks were bungled, and even intentionally embraced, the Foster Wheeler...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

The Volkov Law Group

Gunvor Group Employee Pleads Guilty to FCPA Scheme to Pay Bribes to Ecuadoran Government Officials

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Raymond Kohut, a 68-year old Canadian citizen, a former employee of Swiss commodities trader, Gunvor Group, Ltd., pleaded guilty to paying $22 million in bribes to Ecuadoran government officials at state-owned oil company,...more

Gray Reed

2020's Bad Guys in Energy

Gray Reed on

Larceny, that business enterprise with a knack for (fleeting) success regardless of the state of the economy, was busy last year. As Obi-Wan Kenobe would say it: You will never find a more wretched hive of scum and villainy...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 FCPA Settlement: Lessons Learned (Part III of III)

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The Justice Department is coming to the close of a record FCPA enforcement year despite the disruptions caused by the pandemic. The Vitol case also represents the first parallel prosecution involving the Commodities Futures...more

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