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White Collar Crimes Foreign Corrupt Practices Act (FCPA) Kickbacks

American Conference Institute (ACI)

The DOJ’s New Pilot Programs: A Bane for Compliance Programs

For years, Department of Justice officials have stressed how important chief compliance officers are as the first line of defense in fighting corporate crimes. While that’s true, compliance programs now have a competitor in...more

Polsinelli

Bribes and Kickbacks Don’t Happen in My Organization – I think?

Polsinelli on

The U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act 2010, along with dozens of trade treaties and conventions, forbid consummated (and attempted) improper or unethical payments to government officials or...more

Dechert LLP

Federal Court Rejects DOJ’s Novel and Extraterritorial Effort To Extend FCPA Jurisdiction to Foreign Agents

Dechert LLP on

The United States District Court for the Southern District of Texas recently recognized new constitutional and extraterritorial limits on the FCPA. In an order entered November 10, 2021, the court held that it lacked...more

Thomas Fox - Compliance Evangelist

Novartis US Corruption Settlements: Part 1 – Introduction

I have written extensively about the Novartis International AG (Novartis) Foreign Corrupt Practices Act (FCPA) settlement, which was announced in late June. However, the enforcement action paled next to the Stipulation and...more

Gray Reed

2019 Bad Guys in Energy

Gray Reed on

To our bad guys, 2019 was a year flush with hope and opportunity; it ended with recidivism, more misery from Venezuela, a charlatan, an Okie who pulled a multi-million dollar fast-one on Chesapeake and, as in years past, a...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 – Final Thoughts

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

Thomas Fox - Compliance Evangelist

The Ahsanis’ Information – The Corruption Schemes

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

Ballard Spahr LLP

Two Former Venezuelan Officials and Energy Executives Indicted as DOJ Continues to Use Money Laundering Charges to Combat Foreign...

Ballard Spahr LLP on

Last week, a grand jury in the Southern District of Florida indicted two former Venezuelan officials, charging them with seven counts of money laundering and one count of money-laundering conspiracy. The charges relate to...more

Thomas Fox - Compliance Evangelist

Corruption in China: Part 2 – The Bribery Schemes

After a sidetrack into the ethical train wreck detailed by the SEC Cease and Desist Order re: KPMG yesterday, I am returning to the blog post series I am running based upon the New York Times (NYT) reporting by Alexandra...more

Hogan Lovells

U.S. and Brazilian Authorities Reportedly Cooperating in Investigation of Alleged Bribery and Price Fixing Related to Medical...

Hogan Lovells on

In a May 17, 2019 press report that has been widely distributed in Brazil and the United States, Brazilian Federal Prosecutor Marisa Ferrari confirmed that the U.S. Federal Bureau of Investigation (FBI), the U.S. Department...more

Thomas Fox - Compliance Evangelist

Farewell to Dr. Z: A Guilty Plea and Two Indictments in 1MDB

In a three-count Indictment, another Goldman Sachs employee, Roger Ng, was charged with conspiracy to violate the FCPA and money-laundering. Ng was arrested in Singapore and will presumably be transported to the US to stand...more

The Volkov Law Group

Goldman Sachs and the 1MDB Criminal Prosecutions

The Volkov Law Group on

The 1Malaysia Development Berhad scandal (“1MDB scandal”) has been making headlines for the past few years. The turning point for US prosecutors was the cooperation of Malaysian law enforcement and the corruption allegations...more

The Volkov Law Group

Sanofi Coughs Up $25 Million to Settle SEC FCPA Charges

The Volkov Law Group on

Well, add another pharmaceutical company to the FCPA healthcare “sweep.” Frankly, the term “sweep” makes it sound like a coordinated enforcement effort – instead, it is more accurate to think of it as multiple prosecutions...more

Thomas Fox - Compliance Evangelist

Farewell to Sammartino: The Continued Unraveling of PDVSA Corruption

Yesterday Cesar David Rincon Godoy (Rincon) pled guilty to a massive money laundering scheme which took the proceeds of his corruption while he was employed at PDVSA. According to the DOJ Press Release, Rincon, a citizen of...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

T’Was the Week After Christmas: General Cable and Mexico Aviation FCPA Prosecutions

The Volkov Law Group on

You know this has been a big year in FCPA enforcement when DOJ and the SEC announce two FCPA settlements during the usually sleepy week between Christmas and New Years. And what a year it has been – more to follow in my...more

Thomas Fox - Compliance Evangelist

Put the Candle Back: the AstraZeneca FCPA Enforcement Action

I am back from a two-week summer study program at Oxford, run by Michigan State University through its Odyssey to Oxford program. It was a great experience. My class was on The Tudors in film and print so not only did I...more

The Volkov Law Group

Lessons Learned from AstraZeneca’s $5.5 Million SEC FCPA Settlement

The Volkov Law Group on

Last week, the SEC added another pharmaceutical company to its list of FCPA violators when AstraZeneca agreed to a $5.5 million settlement with the SEC. AZ is now the 25th drug or medical device company to pay an FCPA penalty...more

Thomas Fox - Compliance Evangelist

Red Flags Squelch Corrupt PDVSA Deal

As the Petrobras corruption scandal seems to be going strong, we turn our attention to what may be the most corrupt of all the national energy companies, the Venezuelan state oil company Petroleos de Venezuela SA (PDVSA)....more

Manatt, Phelps & Phillips, LLP

Corporate Investigations and White Collar Defense - June 2016

Eye on the Supreme Court—Corruption and Fraud Edition - Why it matters: This session, the Supreme Court has undertaken the review of numerous cases that raise thorny issues arising in the white collar context. In our...more

Thomas Fox - Compliance Evangelist

Booking a Meeting? In Venezuela It May Cost You a Rolex

First it was Petrobras but it certainly did not take long for the second shoe to drop for the other corrupt national energy company in Latin America, the Venezuelan national oil company Petróleos de Venezuela, also known as...more

The Volkov Law Group

Dissecting a Bribery Violation: Two Important Questions to Answer

The Volkov Law Group on

In the wreckage of a corporate FCPA enforcement action, a company has to answer two important questions. First, how did the conduct occur without senior executives and the Board learning or suspecting that such conduct...more

Thomas Fox - Compliance Evangelist

George Carlin and Erga Omnes: the Petrobras Bribery Scandal Expands

On this date in 2008 George Carlin died. If you grew up in the late 1960s or early 1970s and you had anti-parental or anti-establishment inklings, which of course all teenagers do, you knew about George Carlin. In the early...more

Thomas Fox - Compliance Evangelist

Why Should Americans Care About the FIFA Indictments? Part III – Corruption and US Companies

Today, I continue my four-part series on the above question posed to me recently by a colleague. In Part I, I wrote that only the US government had the wherewithal, tools and will to do so. Yesterday, I focused on corruption...more

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