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In an annual report filed with the SEC on March 20, 2017, ING Groep, N.V., a Netherlands-based financial services company, stated that it is under criminal investigation by Dutch authorities “regarding various requirements related to the on-boarding of clients, money laundering, and corrupt practices,” and that it has also received “related information requests” from U.S. authorities. A spokesperson for the Dutch prosecutor reportedly expressed suspicion that ING failed to report irregular transactions and may have enabled international corruption, including unusual payments made by VimpelCom, the Russian telecom company, to a government official in Uzbekistan through a shell company. VimpelCom settled bribery charges with the U.S. and Dutch governments in February 2016, admitting to paying bribes amounting over $114 million to an Uzbek official and agreeing to pay over $397 million in penalties to the DOJ and SEC for violations of the FCPA. ING stated that it is cooperating with the ongoing investigations and requests of Dutch and U.S. authorities.
On March 30, the Federal Bureau of Investigation ("FBI") announced the establishment of three international corruption squads dedicated to investigating incidents of foreign bribery and kleptocracy-related criminal activity. The squads, based in New York, Los Angeles, and Washington, D.C., will work closely with the DOJ's Fraud Section and the SEC in investigating violations of the FCPA. Special Agent George McEachern, who heads the International Corruption Unit at FBI Headquarters, stated that the squads were created to address the national and international implications of corruption. The establishment of these new dedicated corruption squads has been spurred, at least in part, by the rise in cooperation among regulatory and law enforcement authorities across the globe to investigate and prosecute foreign corruption. Indeed, the FBI press release noted the Bureau's partnerships with overseas law enforcement agencies as well as its participation in international working groups such as the Foreign Bribery Task Force. The increased FBI attention is also notable in the context of the rising use of so-called "traditional" white-collar investigative techniques such as wiretaps and confidential informants in FCPA cases, including in the current PetroTiger prosecution and the DOJ's failed Africa Sting case.
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