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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
Former Comptroller of Ecuador Convicted in International Bribery and Money Laundering Scheme - On April 24, a Miami jury convicted Carlos Ramon Polit Faggioni, the former Comptroller General of Ecuador, for his role in an...more
How the New Law Creates Legal Risks and Opportunities for International Businesses - On December 22, 2023, President Biden signed into law the 2024 National Defense Authorization Act (NDAA), which will give the U.S....more
Three Men Sentenced for $54 Million TRICARE Fraud Scheme - Three men were sentenced in connection with a $54 million bribery and kickback scheme involving TRICARE, a federal program that provides health insurance benefits...more
With it being Lent and all, we ask, are this year’s Ferrymen of the River Styx using these 40 days to turn from wickedness and find their way to repentence? Who knows, but we do know that as alternative energy rises, so do...more
In the legal and compliance space, it is easy to ignore significant incidents involving domestic bribery and fraud. We are fixated on FCPA foreign bribery cases, as well as domestic healthcare fraud, anti-kickback violations...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption developments from the past month, with links to...more
The Justice Department announced the arrest and indictment of Charles Hunter Hobson for violating the FCPA, money laundering and receiving kickbacks arising from a bribery scheme to pay government officials in Egypt in...more
On October 26, Marcus Frazier of New York pled guilty to two counts of wire fraud affecting a financial institution for his alleged role in a scheme to obtain $6.9 million in Paycheck Protection Program (“PPP”) funds designed...more
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more
Deutsche Bank to Pay Over $130 Million to Resolve Foreign Corrupt Practices Act and Fraud Allegations - Deutsche Bank Aktiengesellschaft (Deutsche Bank) has agreed to pay more than $130 million to resolve the government’s...more
Although courts have reined in the application of the Foreign Corrupt Practices Act (FCPA) anti-bribery provisions in the past two years, the US Department of Justice (DOJ) shows no sign of scaling back its global...more
Two recent rulings in separate foreign bribery cases highlight the continued impact of individual prosecutions on the interpretation of various provisions of the Foreign Corrupt Practices Act (FCPA). In United States v....more
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
The Justice Department won another FCPA trial. After a three-week trial, Mark Lambert of Mount Airy, Maryland, was found guilty of four counts of violating the FCPA, two counts of wire fraud and one count of conspiracy to...more
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
The extraterritorial reach of statutes seeking to prohibit unscrupulous financial practices has been debated and watched as both entities and individuals seek to determine the scope of the United States’ government’s ability...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
ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...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