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White Collar Crimes Foreign Corrupt Practices Act (FCPA) Petrobras

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

Thomas Fox - Compliance Evangelist

The Trafigura FCPA Enforcement Action – Part 1 – Introduction

In March 2024, the Department of Justice (DOJ) announced the resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international...more

The Volkov Law Group

DOJ and CFTC Close Out Slow FCPA Enforcement Year with $98 Million Resolution with Freepoint Commodities LLC (Part I of II)

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The Justice Department’s FCPA enforcement record for 2024 was slow.  This  trend was unexpected, contrary to my own predictions and of various other prognosticators.  It is hard to explain why this slowdown occurred....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

Lessons Learned from the Honeywell FCPA Settlement (Part III of III)

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The Honeywell FCPA settlement underscored a number of important issues – lessons learned for compliance professionals.  Every FCPA case carries important lessons learned, but some more than others....more

The Volkov Law Group

Digging into Honeywell UOP’s Bribery Schemes in Brazil and Algeria (Part II of III)

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The facts surrounding Honeywell’s bribery schemes in Brazil and Algeria are fairly straightforward.  In Brazil, the facts underscore the significant risks of bribery when companies participate in large, valuable project...more

The Volkov Law Group

DOJ and SEC Close Year with FCPA Settlement with Honeywell UOP for $160 Million (Part I of III)

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The Justice Department and the Securities and Exchange Commission had a strong FCPA enforcement year.  However, there is certainly more to come and it is easy to predict that 2023 will be even a bigger year....more

The Volkov Law Group

Tenaris Pays SEC $78 Million to Resolve FCPA Violations

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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

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

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

The Volkov Law Group

Vitol Pays $163.7 Million to Settle FCPA Case (Part I of III)

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The Justice Department continues to produce FCPA resolutions in a record year for enforcement.  The latest, and perhaps the beginning of several end-of-year and end of the Trump Administration resolutions, is DOJ’s settlement...more

The Volkov Law Group

DOJ FCPA Settlement: J&F Investmentos’ Bribery Schemes (Part II of V)

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J&F’s Investmentos bribery scheme was pervasive and was coordinated with a senior Brazilian Finance minister and orchestrated through the use of United States banking.  The Brazilian official appears to be Guido Mantega, who...more

Thomas Fox - Compliance Evangelist

Lessons Learned from the Samsung FCPA Enforcement Action

Last week, another Foreign Corrupt Practices Act (FCPA) case was resolved. It involved Samsung Heavy Industries Company Limited (SHI), a South Korea-based engineering company that provides shipbuilding, offshore platform...more

The Volkov Law Group

Review of Samsung’s Bribery Scheme in Brazil (Part II of II)

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Samsung’s recent FCPA settlement with the Justice Department capped yet another example of a company involved in bribing Petrobas in Brazil for valuable contracts.  The scope of the bribery scheme was focused on a contingent...more

The Volkov Law Group

Samsung Agrees to Pay $75 Million to Resolve FCPA Violations (Part I of II)

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Samsung Heavy Industries agreed with the Justice Department to pay $75 million to settle FCPA charges. Under a three-year deferred prosecution agreement (DPA), Samsung agreed to filing of a criminal information in the Eastern...more

Thomas Fox - Compliance Evangelist

TechnipFMC FCPA Enforcement Action: Part 2 – The Bribery Schemes

Last week there was the TechnipFMC plc (TechnipFMC) Foreign Corrupt Practices Act (FCPA) enforcement action, which was settled via a Deferred Prosecution Agreement (DPA)for TechnipFMC and a guilty pleafrom the company’s US...more

The Volkov Law Group

2018 FCPA Year in Review: The More Things Change, The More They Stay the Same

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Happy New Year! Another year is in the books for FCPA enforcement and compliance. The headline for this past year (like many other years) is/was – The more things change, the more they stay the same....more

BCLP

Anti-Corruption Enforcement Webinar: 2018 in Review

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Anti-Corruption enforcement remained a top priority in France, the UK, and the US in 2018. Join our firm's Global Anti-Corruption Team as they explain and analyze these three countries' anti-corruption enforcement efforts and...more

The Volkov Law Group

Vantage Drilling Forks Over $5 Million for SEC FCPA Settlement

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The SEC announced last week a $5 million FCPA settlement with Vantage Drilling International (“Vantage”), a Texas-based offshore drilling company. ...more

Thomas Fox - Compliance Evangelist

The NPA; The Petrobras FCPA Enforcement Action: Part III

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

The Volkov Law Group

Petrobas Closes Out “Massive” Corruption Investigations and Litigation

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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

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