Foreign Corrupt Practices Act & Anti-Corruption
Lawyers of the highest integrity who are extremely bright and on top of changes in the law and government enforcement priorities, and are respected and trusted by government prosecutors.Legal 500
Practice Overview
Buckley lawyers advise on all aspects of the Foreign Corrupt Practices Act (FCPA) and anti-corruption law. Whether our clients are building or testing compliance programs, or caught in the cross-hairs of criminal or civil FCPA enforcement, we help them determine the most cost-effective, risk-based response to any anti-corruption scenario.
Our difference is our ability to support any course of action chosen by our clients, around the world. In the U.S., we have deep experience with FCPA prosecutors, both criminal and civil, and are one of the few firms to ever take the government to court — and win — in FCPA matters. We also work in collaboration with counsel worldwide in coordinated multi-jurisdiction enforcement defense matters. We have conducted internal investigations across the globe, including in Europe, Asia, Africa, and the Middle East; collaborated with local counsel on anti-corruption compliance matters in over a dozen non-U.S. jurisdictions; served as on-call counsel for our clients’ most challenging compliance matters; implemented corruption risk due diligence programs in a number of countries; and conducted numerous top-to-bottom reviews of corporate compliance programs.
We pride ourselves on understanding the details of our clients’ businesses, and in bringing sound and practical advice to any counseling circumstance. We know anti-corruption doctrine and best practices, and work with our clients to ensure that these principles remain intact while still getting business done. This integrated approach pays dividends if an enforcement matter arises. We immediately understand how to evaluate corruption risks and compliance solutions. Moreover, our enforcement work guides our counseling so that new trends and risks are identified and mitigated.
Our team includes several former government enforcement officials, including a 20-year veteran of the Securities and Exchange Commission’s (SEC) Enforcement Division, who investigated numerous high-profile FCPA actions and later served as Chief of the Office of Market Intelligence, where he founded and oversaw the SEC’s whistleblower program. Also on our team are long-time Assistant United States Attorneys from the District of Columbia who have tried dozens of criminal cases, as well as FCPA defense veterans. We have been a part of some of the most significant criminal and civil FCPA cases of recent years, including the successful four-month criminal trial defense of a defendant in the FCPA/Africa Sting cases, as well as one of the few SEC FCPA civil actions ever to reach a courtroom. Legal 500 noted our FCPA work, calling it an “area in which the team has ‘deep and relevant experience.’”
Examples of our current or recent FCPA representations include:
- Defending against multi-jurisdictional government investigations and civil litigation: Representing Universal Entertainment Corp., a large Japanese gaming manufacturer, and its subsidiary, Aruze USA, Inc., in FCPA-related litigation brought by Wynn Resorts Ltd., as well as in related parallel matters; the case involves one of the first examples of a private party alleging FCPA violations as a method to gain an upper hand in a contract dispute
- Conducting internal investigations, negotiating FCPA resolutions, and improving compliance structures: Represented The Dow Chemical Company in an FCPA case involving a fifth-tier subsidiary in India, resulting in a settled, no-admission action with the SEC, which agreed not to impose a compliance monitor
- Criminal trial defense: Represented an individual (John Mushriqui) indicted as part of the “FCPA Sting” case, the largest FCPA criminal enforcement proceeding against individuals ever brought by the DOJ, following the only modern use by the FBI in an FCPA case of tactics such as a sting, an informant, undercover agents, and mass use of audio-visual surveillance; following a four-month trial, the DOJ dismissed all charges
- Civil enforcement / SEC litigation defense: Represented Mark Jackson, the former CEO/CFO of oilfield services company Noble Corp., in an SEC enforcement action brought in federal court. Following hotly contested litigation, the SEC agreed on the eve of trial to settle the matter without our client paying any money and without any restriction on his future employment opportunities
Lawyers of the highest integrity who are extremely bright and on top of changes in the law and government enforcement priorities, and are respected and trusted by government prosecutors.Legal 500
Articles
Taking a Deposition Abroad - It's Not Mission Impossible
Imagine that your client, a multi-national enterprise, is the target of an investigation by the US government into violations of the Foreign Corrupt Practices Act. All of a sudden, plaintiffs' lawyers are circling in federal and state courts, looking to make a civil case out of any alleged...
ArticlesIndividual and Coordinated Prosecutors Accelerate - Along With The Challenges
For years, federal and state prosecutors have touted their willingness to charge individuals as an essential deterrent to white-collar criminal action, often responding to criticism of prosecutions of corporate entities without any accompanying prosecution of related executives. And for years,...
ArticlesWriting the Facilitating Payments Exception Out of the FCPA
Last summer, a lawsuit brought by the Securities and Exchange Commission (SEC) alleging Foreign Corrupt Practices Act (FCPA) violations against two individuals related to Noble Corporation, a global oil and gas drilling services company, nearly went to trial in federal court in Texas. SEC v...
ArticlesMind Your Flanks: Collateral Litigation Associated with FCPA Actions
When allegations of foreign bribery surface — whether from news reports, a whistleblower submission, or otherwise — companies move aggressively to address the many issues associated with a potential investigation by the U.S. Department of Justice (DOJ) and/or the U.S. Securities and Exchange...
ArticlesFCPA: Were the Sting Trials Doomed From the Start?
When the jury in the second Foreign Corrupt Practices Act (FCPA) Sting case trial came back with two acquittals, and hung on three other defendants, the impact of the Department of Justice's (DOJ) ambitious FCPA enforcement efforts was apparent. United States v. Goncalves et al. , No. 09-335 (D.D.C...
ArticlesSeven Steps Companies Can Take to Incentivize Internal Reporting of FCPA Violations
At present, the SEC's Whistleblower Office is receiving about eight whistleblower tips per day, and that number is likely to increase after the first whistleblower is paid. That award is expected shortly. If companies take steps now to enhance their internal reporting policies and procedures, they...
ArticlesFCPA Update: A Busy December: Highlights of Recent FCPA Enforcement Activity Involving Individuals
This month brought a string of developments related to individual enforcement actions under the US Foreign Corrupt Practices Act. Our partner David Krakoff just secured dismissal of three of six charges against one of the defendants in the long-running criminal FCPA trial here in Washington, D.C.,...
Articles2011 Anti-Corruption Activity in India
James Parkinson authored "2011 Anti-Corruption Activity in India," in The International Lawyer (ABA Section of International Law, 2011 Year-in-Review). This article will be published in Spring 2012.
ArticlesCorruption in Emerging Markets
James Parkinson & Leslie Meredith authored the chapter, "Corruption in Emerging Markets" in the upcoming publication, The US Private Equity Compliance Companion to be published in January 2012.
Articles
News & Blogs
OFAC sanctions Iranian entities and individuals supporting intelligence gathering and cyber targeting of U.S. persons
On February 13, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against an Iran-based entity and four affiliated Iranian individuals for their alleged roles in providing support for the Islamic Revolutionary Guard Corps-Qods Force’s (IRGC-QF) efforts to...
InfoBytesU.S. Treasury concerned with European Commission's identification of AML/CFT-deficient U.S. territories
On February 13, the U.S. Treasury Department issued a statement responding to a list of jurisdictions published by the European Commission as having strategic deficiencies related to anti-money laundering and countering the financing of terrorism (AML/CFT). The list—which includes certain...
InfoBytesMicronesian official charged with money laundering conspiracy after guilty plea to bribery by Hawaiian executive
On February 11, the Department of Justice (DOJ) unsealed conspiracy to commit money laundering charges against a Micronesian government official alleged to have taken bribes to secure engineering and project management contracts from the government of the Federated States of Micronesia (FSM). The...
FCPA ScorecardOFAC amends Venezuela-related General Licenses and FAQs on sanctioned oil company
On February 11, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) amended two General Licenses (GL) and issued three revised FAQs regarding sanctions against Venezuela’s state-owned oil company pursuant to Executive Order 13850. GL 3C , which supersedes GL 3B, authorizes...
InfoBytesOFAC designates Turkish individual as “Foreign Sanctions Evader” in relation to settlement resolving alleged Iranian sanctions violations
On February 7, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $13,381 settlement with a Virginia-based corporation on behalf of its Turkish affiliate for six alleged violations of the Iranian Transactions and Sanctions Regulations (ITSR). The settlement resolves...
InfoBytesFormer Petrofac oil-services sales executive pleads guilty in U.K. to bribery charges
On February 6, the U.K. SFO announced that a former sales executive, David Lufkin, of an oil-services company, Petrofac PLC, had pleaded guilty in the U.K. to 11 counts of bribery regarding payments made in exchange for winning oil-services contracts in Iraq and Saudi Arabia. Lufkin – a British...
FCPA ScorecardOFAC revises Venezuela-related General Licenses on sanctioned oil company, issues new FAQs
On February 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) amended two General Licenses (GL) and issued two new FAQs regarding sanctions against Venezuela’s state-owned oil company pursuant to Executive Order 13850. OFAC amended GL 3B to authorize transactions related to...
InfoBytesOFAC reaches settlement with cosmetics company for alleged North Korean sanctions violations
On January 31, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $996,080 settlement with a California-based cosmetics company for 156 alleged violations of the North Korean Sanctions Regulations. According to OFAC, the settlement resolves potential civil liability...
InfoBytesFormer insurance executives charged with laundering bribes to Barbados Minister of Industry
On January 28, DOJ announced charges against the former chief executive and a former senior vice president of a Barbados-based insurance company, Insurance Corporation of Barbados Limited (ICBL). The indictment alleges that the ICBL executives, Ingrid Innes and Alex Tasker, participated in a scheme...
FCPA ScorecardOFAC announces sanctions against Venezuela’s state-owned oil company; President Trump issues related Executive Order
On January 28, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against Venezuela’s state-owned oil company pursuant to Executive Order 13850 (E.O. 13850). According to OFAC, the designation follows a determination made by the Secretary of the Treasury that...
InfoBytesOFAC lifts sanctions on designated companies linked to Russian oligarch
On January 27, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) lifted sanctions on three companies identified last April in connection with sanctions imposed against a Russian oligarch. (See previous InfoBytes coverage here on the full list of sanctioned Russian oligarchs and...
InfoBytesOFAC issues temporary extension of Ukraine-related General Licenses
On January 16, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced the issuance of Ukraine-related General Licenses (GL) 13J, 14E, and 16E, which modify the expiration dates of previous Ukraine-based general licenses for wind-down transactions for certain companies that...
InfoBytesTreasury Department sanctions Venezuelan TV mogul over Venezuelan bribery scheme
On January 8, the Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned Venezuelan individuals and companies, including billionaire news network Globovision owner Raul Gorrin Belisario and former Venezuelan National Treasurer Claudia Patricia Diaz Guillen, for their participation...
FCPA ScorecardOFAC adds illicit foreign exchange operation participants to Specially Designated Nationals List; issues Venezuela-related General License and new FAQ
On January 8, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced additions to the Specially Designated Nationals List pursuant to Executive Order 13850 . OFAC’s additions to the list include seven individuals—including former Venezuelan government officials—and 23...
InfoBytesEletrobras reaches settlement of FCPA violations in Brazil
On December 26, Brazil’s Centrais Elétricas Brasileiras S.A. – Eletrobras (Eletrobras or the company) entered into an administrative order to settle the SEC’s claims that Eletrobras violated the books and records and internal accounting controls provisions of the FCPA and agreed to pay a civil...
FCPA ScorecardPolycom reaches settlement of FCPA violations in China
On December 26, Polycom, Inc. (Polycom or the company), a wholly-owned subsidiary of Plantronics, Inc., entered into an administrative order to settle claims by the SEC that Polycom violated the books and records and internal accounting controls provisions of the FCPA. The alleged conduct involved...
FCPA ScorecardUK court convicts former Alstom executive
On December 19, a UK Court found former Alstom Power Ltd. Global Sales Director Nicholas Reynolds guilty of conspiracy to corrupt in connection with his role in bribing Lithuanian officials to win lucrative power station contracts for the French power and transportation company. Mr. Reynolds will...
FCPA ScorecardNY-based financial institution and various individuals charged in Malaysia
On December 17 and 19, press reports indicate Malaysian prosecutors filed criminal charges against a New York-based financial institution and numerous individuals, including former executives of the financial institution, in connection with their alleged roles in a multi-billion bribery and money...
FCPA ScorecardSEC charges former senior executives of Panasonic Avionics
On December 18, the former CEO and CFO of U.S.-based Panasonic Avionics Corporation (PAC) settled SEC charges that they knowingly violated books and records and internal accounting controls provisions of the federal securities laws and caused similar violations by PAC’s parent company, Osaka, Japan...
FCPA ScorecardOECD study finds that government officials punished in only one-fifth of bribery cases
On December 11, the Organization for Economic Cooperation and Development (OECD) published a study examining the consequences faced by public officials who allegedly accepted bribes. The study analyzed 55 foreign-bribery cases concluded between 2008 and 2013 in which companies based in OECD...
FCPA ScorecardFormer officer of Venezuela oil company pleads guilty to obstruction
On December 10, a former procurement officer of Petroleos de Venezuela S.A. (PDVSA), Venezuela’s state-owned and state-controlled energy company, pleaded guilty to one count of obstructing an investigation into bribes paid by the owner of U.S.-based companies to Venezuelan government officials in...
FCPA ScorecardLauren R. Randell quoted in Business Insurance article, “DOJ policy shift could trigger increased demand for D&O cover”
Lauren R. Randell was quoted on December 11, 2018 in a Business Insurance article, “DOJ policy shift could trigger increased demand for D&O cover,” which discussed Deputy U.S. Attorney General Rod Rosenstein’s announcement of modifications to the “Yates memo” — the 2016 Memorandum on Individual...
In The NewsU.S.-based agriculture company discloses investigation
On November 30, a U.S.-based agriculture company, CHS Inc., disclosed in an SEC filing that it is cooperating with an investigation being conducted by the SEC and DOJ involving payments made to Mexican customs officials. The payments were made in connection with grain shipments crossing the U.S.-...
FCPA ScorecardUK Serious Fraud Office ends first deferred prosecution agreement with Standard Bank
On November 30, the United Kingdom’s Serious Fraud Office (SFO) announced the successful conclusion of the deferred prosecution agreement entered into in 2015 with Standard Bank PLC, which had followed allegations that payments were made by two former employees to bribe members of the Tanzanian...
FCPA ScorecardBuckley Sandler Special Alert: DOJ announces new policy on pursuing individuals in corporate resolutions
U.S. Deputy Attorney General Rod Rosenstein said at a conference this morning that the U.S. Department of Justice has revised its guidelines relating to corporate resolutions with the DOJ, particularly as those guidelines relate to charging culpable individuals. The revised guidelines modify the...
FCPA ScorecardSEC settles with Texas offshore drilling company for violations of FCPA internal controls provision
On November 19, the SEC announced a settlement with Vantage Drilling International (“Vantage”) based on the improper activities of Vantage’s predecessor, Vantage Drilling Company, in connection with the Petrobras bribery scheme. The Administrative Order found that Vantage Drilling Company had “...
FCPA ScorecardCo-conspirators sentenced in Venezuelan bribery scheme involving Venezuelan TV mogul
Two co-conspirators of billionaire news network Globovision owner Raul Gorrin Belisario were sentenced this week as part of the DOJ’s recently unsealed prosecution of a bribery scheme involving over $1 billion paid in bribes to members of the Venezuelan government. According to the DOJ , Gorrin was...
FCPA ScorecardSEC releases 2018 report on whistleblower program
On November 15, the SEC released its 2018 Annual Report to Congress on its Whistleblower Program , as required under § 924(d) of the Dodd-Frank Act and § 21(F)(g)(5) of the Securities Exchange Act of 1934. The Report, which covers October 1, 2017 through September 30, 2018, indicates that the SEC...
FCPA Scorecard9th Circuit hears oral arguments on overturning FCPA whistleblower retaliation award
On November 14, 2018, a three judge panel for the United States Court of Appeals for the Ninth Circuit heard oral arguments in Sanford Wadler v. Bio-Rad Laboratories, Inc., et al . Bio-Rad, a life science research and diagnostics company, is hoping to overturn a February 2017 jury verdict ordering...
FCPA ScorecardU.S. financial institution acknowledges investigations related to Malaysian development fund scheme
On November 2, a New York-based financial institution disclosed in its Form 10-Q filing that it had received subpoenas and requests for documents and information from multiple government agencies as part of investigations relating to matters involving 1Malaysia Development Berhad (1MDB). The filing...
FCPA ScorecardOil company executives found guilty in U.K. of money laundering
According to the U.K Serious Fraud Office (SFO), the former CEO and CFO of Afren, Plc., an oil and gas exploration and production company, were sentenced in the UK on October 29 for their parts in a kickback scheme in Nigeria. The former CEO was sentenced to up to six years in prison, and the CFO...
FCPA ScorecardU.S. announces charges and guilty plea stemming from Malaysian development fund scheme
The DOJ unsealed two indictments and a guilty plea related to the sprawling 1Malaysia Development Berhad (1MDB) fraud on November 1 in the Eastern District of New York. Malaysian financier Low Taek Jho (also known as Jho Low) and former banker Ng Chong Hwa (also known as Roger Ng) were charged with...
FCPA ScorecardFormer PDVSA procurement officer pleads guilty
On October 30, 2018, a Texas businessman, Ivan Alexis Guedez, who was a former procurement officer for PDVSA, pleaded guilty to conspiracy to launder the bribe payments he and his co-conspirators at PDVSA received for directing PDVSA business to a Miami-based supplier. The scheme involved false...
FCPA ScorecardSwiss banker sentenced to 10 years related to PDVSA embezzlement and bribery scheme, and PDVSA official pleads guilty in same scheme
On October 29, Matthias Krull, a former banker at Julius Baer, was sentenced to serve 10 years in prison for his role in a scheme to launder funds embezzled from Petróleos de Venezuela, S.A. (PDVSA), the Venezuelan state-owned oil company. Krull had pleaded guilty to one count of conspiracy to...
FCPA ScorecardCEO of Haitian development & reconstruction company charged in bribery scheme
On October 30, the DOJ charged Roger Richard Bouncy, a dual U.S.-Haitian citizen, with conspiracy to violate the FCPA, commit money laundering, and violate the Travel Act, as well as substantive Travel Act violations. Bouncy is a licensed attorney and the CEO of Haiti Invest, LLC, a Haitian...
FCPA ScorecardDOJ issues new guidance regarding corporate monitors
On October 11, Assistant Attorney General Brian A. Benczkowski issued a memorandum to the DOJ’s Criminal Division that revises the framework for assessing when DOJ will require a corporate monitor as part of a resolution. Under the revised framework, Criminal Division attorneys must now consider...
FCPA ScorecardInterpol chief detained in China on bribery allegations
In late September, Meng Hongwei, the Chief of Interpol at the time and a former Vice Minister of China’s national police, reportedly went missing during a trip home to China. According to his wife, Meng’s last known communication was a text message to her containing a knife emoji and an instruction...
FCPA ScorecardSEC enforcement director gives remarks on FCPA compliance
On October 3, 2018, Steven Peiken, Co-Director of the SEC’s Division of Enforcement, offered remarks at a white collar crime conference in New York City, discussing a range of issues related to FCPA compliance and enforcement. For example, likely responding to increasing criticism about the...
FCPA ScorecardDOJ provides further guidance on FCPA Corporate Enforcement Policy in speech
On September 27, Deputy Assistant Attorney General Matthew Miner gave a speech that provided clarification of DOJ enforcement policies, continuing to emphasize voluntary disclosure and underscoring the notion that companies should view DOJ “as partners, not adversaries.” In his speech, Miner...
FCPA ScorecardDOJ reportedly investigating Major League Baseball for potential FCPA violations
Based on media reports, DOJ’s Fraud Section is reportedly investigating some part of Major League Baseball (MLB) for possible FCPA violations related to recruitment of international players, particularly related to immigration issues for players from Latin America. Reports indicate that the...
FCPA ScorecardSBM CEO and executive sentenced to prison for conspiracy to bribe foreign officials
On September 28, the DOJ announced that a former CEO and a former executive of oil services company SBM Offshore, N.V. (SBM) had been sentenced to prison and fined for their roles in a scheme to bribe foreign government officials in Brazil (at Petrobras), Angola (Sonangol), and Equatorial Guinea (...
FCPA ScorecardSEC settles FCPA accounting violations with Stryker
On September 28, the SEC announced a settlement with a Michigan-based medical device company, Stryker Corp., to resolve the SEC’s charges of books and records and internal controls violations. According to the order , the company agreed to pay a $7.8 million penalty and accepted the imposition of...
FCPA ScorecardPetrobras settles FCPA violations for $853 million to U.S. and Brazil
On September 27, 2018, the DOJ announced that Petrobras, the Brazilian state-owned oil company, had entered into a Non-Prosecution Agreement with the DOJ, as well as settlement agreements with the SEC and Brazilian authorities, and agreed to pay a total $853.2 million in penalties to all...
FCPA ScorecardSEC settles FCPA charges with former CEO of Chilean mining company
On September 25, 2018, the SEC announced a settlement of FCPA charges against the former CEO of Chilean-based chemical and mining company Sociedad Química y Minera de Chile, S.A. (SQM) for $125,000. According to the SEC, over the course of seven years, SQM’s then-CEO Patricio Contesse González “...
FCPA ScorecardClass certification granted to hedge fund investors
On September 14, a New York federal district court granted class certification to a group of shareholder investors suing an American hedge fund management firm and two of its senior executives on the grounds that the investors were misled about a government investigation into the company’s...
FCPA ScorecardFinancial advisor pleads guilty to money laundering in PetroEcuador case
On September 11, a Miami-based financial advisor pleaded guilty to one count of conspiracy to commit money laundering in connection with his role in making corrupt payments to officials of Ecuador’s state-owned and state-controlled energy company, Empresa Pública de Hidrocarburos del Ecuador (...
FCPA ScorecardUnited Technologies settles FCPA charges with SEC
On September 12, the SEC announced that United Technologies Corporation (UTC) agreed to pay $13.9 million to settle FCPA charges related to payments made through a subsidiary in connection with the sales of elevator and airline equipment in Azerbaijan and China. According the SEC’s Order , from...
FCPA ScorecardDOJ secures additional guilty pleas in wide-ranging PDVSA case
On September 13, the DOJ announced two additional guilty pleas in its wide-ranging foreign bribery investigation into payments to officials of Venezuela’s state-owned energy company, Petroleos de Venezuela S.A. (PDVSA). Juan Carlos Castillo Rincon (Castillo), a former manager of a Texas-based...
FCPA ScorecardReal estate broker and nephew of former UN Secretary-General sentenced for trying to bribe a foreign official
On September 6, U.S. District Judge Edgardo Ramos of the Southern District of New York reportedly sentenced real estate broker Joo Hyuan Bahn, also known as Dennis Bahn, to six months in prison for trying to pay $2.5 million in bribes to a Qatari official in connection with a sale of a high rise...
FCPA ScorecardING settles corrupt practices case in the Netherlands for approximately $900 million and receives SEC declination
On September 4, the Netherlands-based financial services company ING Groep, N.V. announced in its Form 6-K filing that it had agreed to pay a penalty of $782 million and disgorgement of $115 million to resolve corruption charges by the Dutch Public Prosecution Service (“DPPS”). The DPPS charges...
FCPA ScorecardEnsco receives double declination in FCPA investigation
On September 4, Ensco PLC, a London-based offshore drilling company, announced in its Form 8-K filing that the DOJ and the SEC will not take action against the company, ending their investigations into alleged corruption related to a drilling services agreement between Pride International LLC (“...
FCPA ScorecardSanofi settles FCPA action with SEC for $25.2 million
On September 4, the SEC announced that French pharmaceutical company Sanofi S.A. had agreed to pay $25.2 million to settle FCPA charges related to payments made by company employees to healthcare professionals in Kazakhstan and the Middle East. According to the SEC’s order , from 2011 to 2015,...
FCPA Scorecard2nd Circuit rules that FCPA does not reach foreign individuals without their own ties to U.S.
On August 24, the 2nd Circuit rejected the government’s argument for a broad interpretation of personal jurisdiction in FCPA cases, ruling that a non-resident foreign national lacking sufficient ties to a U.S. entity cannot be charged with conspiracy to violate the FCPA or with aiding and abetting...
InfoBytesSecond Circuit rules that FCPA does not reach foreign individuals without their own ties to U.S.
On August 24, the Second Circuit rejected the government’s argument for a broad interpretation of personal jurisdiction in FCPA cases, ruling in United States v. Hoskins that a non-resident foreign national lacking sufficient ties to a U.S. entity cannot be charged with conspiracy to violate the...
FCPA ScorecardSEC issues administrative order against U.S.-based global investment management firm
On August 27, the SEC issued an administrative order settling allegations against a U.S.-based investment management firm, which remained outstanding after the company’s June 4 NPA with the DOJ. The June 4 NPA resolved claims of FCPA violations in Libya and included a criminal penalty of $32.6...
InfoBytesBarbadian insurance company receives first declination with disgorgement under FCPA corporate enforcement policy
On August 23, a Barbadian insurance company received the first declination with disgorgement from the DOJ under the FCPA Corporate Enforcement Policy , which was made effective in November 2017. The conduct at issue involved payments made by the company to a Barbadian official in exchange for...
InfoBytesGlobal technology company confirms U.S. investigations into Hungarian sales operations
On August 23, the Wall Street Journal reported that a global technology company is under investigation by the DOJ and the SEC regarding whether bribes and kickbacks were paid to Hungarian officials connected to sales of the company’s products in Hungary. The company stated in response to the...
InfoBytesBarbadian insurance company receives first declination with disgorgement under FCPA Corporate Enforcement Policy
On August 23, the Insurance Corporation of Barbados Limited (ICBL) received the first declination with disgorgement from the DOJ under the FCPA Corporate Enforcement Policy , which was made effective in November 2017. The conduct at issue involved payments made by ICBL to a Barbadian official in...
FCPA ScorecardSEC issues administrative order against investment manager Legg Mason
On August 27, the SEC issued an administrative order settling allegations against Maryland-based investment manager Legg Mason which remained outstanding after the company’s June 4 NPA with the DOJ. The June 4 NPA resolved claims of FCPA violations in Libya and included a criminal penalty of $32.6...
FCPA ScorecardMicrosoft confirms U.S. investigations into Hungarian sales operations
On August 23, the Wall Street Journal reported that Microsoft is under investigation by the DOJ and the SEC regarding whether bribes and kickbacks were paid to Hungarian officials connected to sales of Microsoft products in Hungary. Microsoft stated in response to the reporting that it had...
FCPA ScorecardGlobal bank settles two FCPA actions for $10.5 million
On August 16, the SEC announced that a global bank had settled two enforcement actions involving alleged violations of the FCPA’s books and records and internal control provisions. The FCPA’s anti-bribery provisions were not implicated in either action. The first action alleged that three traders...
FCPA ScorecardUK SFO charges former Güralp Systems employees with bribery conspiracy as DOJ declines to prosecute the company for FCPA violations
On August 17, the UK Serious Fraud Office (SFO) announced that it was charging two former employees of Reading-based engineering company Güralp Systems Ltd. with “conspiracy to make corrupt payments.” The SFO alleged that the founder and former Managing Director of the company, Cansun Güralp and...
FCPA ScorecardColombia’s former anti-corruption chief pleads guilty to money laundering conspiracy related to foreign bribes
On August 14, the DOJ announced that Colombia’s former National Director of Anti-Corruption, Luis Gustavo Moreno Rivera, pleaded guilty to “participat[ing] in a conspiracy to launder money with the intent to promote foreign bribery.” A Colombian attorney, Leonardo Luis Pinilla Gomez, also pleaded...
FCPA ScorecardFormer Malaysia Prime Minister charged with money laundering
On August 8, Malaysia’s former Prime Minister Najib Razak pleaded not guilty to money laundering charges filed against him in Malaysia in connection with the ongoing investigation of state fund 1MDB. Razak had previously pleaded not guilty to three charges of criminal breach of trust and one charge...
FCPA ScorecardFormer Barbadian Minister of Industry charged with money laundering
On August 6, the Department of Justice announced the arrest and first court appearance of Donville Inniss, former Minister of Industry of Barbados, who DOJ has charged with “laundering bribes that he allegedly received from a Barbadian insurance company in exchange for official actions he took to...
FCPA ScorecardAnother executive arrested in PDVSA bribery case
On August 1, DOJ announced the arrest of Jose Manuel Gonzalez Testino, a dual U.S.-Venezuelan citizen, on foreign bribery charges for making and conspiring to make corrupt payments to an official of Venezuela’s state-owned energy company, Petroleos de Venezuela S.A. (PDVSA). Gonzalez was arrested...
FCPA ScorecardCourt dismisses SEC allegations against executives of hedge fund management firm as time-barred
Judge Nicholas Garaufis of the Eastern District of New York issued a 32-page memorandum opinion this week dismissing the SEC’s civil suit against two former executives of an American hedge fund management firm (earlier coverage can be found here and here ). The SEC’s complaint alleged that the...
FCPA ScorecardLatest conviction in PDVSA bribery case
On July 16, 2018, Luis Carlos De Leon-Perez, a dual U.S.-Venezuelan citizen, pleaded guilty to one count of conspiracy to violate the FCPA and one count of conspiracy to commit money laundering. De Leon’s convictions relate to allegations that he bribed officials at Venezuela’s state-owned oil...
FCPA ScorecardGlobal bank pays $76.7 million to settle hiring practices case
A global bank and its Hong Kong subsidiary reached a settlement with the DOJ and the SEC related to its alleged practice of “awarding employment to friends and family of Chinese officials” to win business. The subsidiary agreed to pay a $47 million criminal penalty as part of a non-prosecution...
FCPA ScorecardSEC settles with Beam Suntory for $8.2 million regarding India payments
On July 2, the SEC settled FCPA allegations with alcoholic beverage company Beam Suntory, Inc. (“Beam”) in an administrative proceeding stemming from alleged FCPA violations from 2006 through 2012. Beam neither admitted nor denied any wrongdoing. The SEC alleged that the company’s subsidiary in...
FCPA ScorecardAruban telecom official sentenced for money laundering conspiracy involving FCPA violations
On June 27, Judge Frederico Moreno of the United States District Court of the Southern District of Florida sentenced Egbert Yvan Ferdinand Koolman, an official of Servicio di Telecommunicacion di Aruba N.V. (Setar), to 36 months in prison following his guilty plea for money laundering charges in...
FCPA ScorecardNon-profit advocacy organizations accuses Bank of England of deceptive report on US whistleblower tip rewards programs
On June 20, the National Whistleblower Center, an American non-profit advocacy organization for whistleblowers, and the European Center for Whistleblower Rights formally requested that the Bank of England retract a report that they allege s mischaracterizes US whistleblower tip rewards programs,...
FCPA ScorecardGlobal bank settles FCPA allegations concerning “sons and daughters” investigation into hiring practices
On June 6, a global bank announced it had entered into a non-prosecution agreement with the DOJ to resolve an FCPA investigation into hiring practices in the Asia Pacific region between 2007 and 2013. As part of the agreement, the bank agreed to pay a $46 million penalty to the DOJ. According to...
FCPA ScorecardLegg Mason settles FCPA allegations with DOJ
On June 4, the DOJ announced that Legg Mason, a Baltimore-based investment management firm, had entered into a non-prosecution agreement and agreed to pay $64.2 million to resolve FCPA allegations in connection with the firm’s involvement in Libya through Permal, a London-based fund purchased by...
FCPA ScorecardSociété Générale settles FCPA allegations concerning bribery of Libyan officials
On June 4, the DOJ announced that Société Générale S.A., a Paris-based multinational bank, and its wholly owned subsidiary SGA Société Générale Acceptance N.V., agreed to pay $585 million to resolve charges in the United States and France involving bribes to Libyan officials. According to the DOJ,...
FCPA ScorecardLegg Mason preparing for FCPA settlement
On May 30, Legg Mason, a Baltimore-based investment management firm, announced in a 10-K SEC filing that it will soon complete negotiations with the DOJ and SEC to resolve FCPA allegations stemming from how Permal, a London-based fund purchased by Legg Mason in 2005, managed assets of Libyan...
FCPA ScorecardMacau real estate developer sentenced for bribing UN officials
On May 11, Judge Vernon S. Broderick of the SDNY sentenced Macau real estate developer Ng Lap Seng to 48 months in prison and ordered him to pay a $1 million fine, $302,977 in restitution, and forfeiture of $1.5 million. In July 2017, a jury convicted Ng of two counts of violating the FCPA, one...
FCPA ScorecardBrother of Honduran government official indicted for laundering bribes in New Orleans
On May 1, the Department of Justice announced the indictment of a Honduran national, Carlos Alberto Zelaya Rojas, for trying to launder more than $1.3 million in bribes that had been paid to his brother, the former Executive Director of the Honduran Institute of Social Security. The bribes had been...
FCPA ScorecardDOJ issues new policy against “piling on” in corporate enforcement, FCPA cases
On May 9, the DOJ issued a new policy to discourage “piling on” in corporate enforcement cases, including those involving the FCPA. The new policy directs the DOJ to “consider the totality of fines and penalties” being imposed by the DOJ and other law enforcement agencies on a company for the same...
FCPA ScorecardClear Channel Outdoor discloses potential FCPA violations
On April 30, Clear Channel Outdoor, one of the world’s largest outdoor advertising companies, disclosed that it had self-reported potential FCPA violations to the SEC and DOJ. The San Antonio-based company had previously disclosed that Chinese police were investigating “several employees” of its...
FCPA ScorecardPanasonic settles parallel FCPA actions for $280 million
On April 30, a DOJ deferred prosecution agreement and SEC settlement with Japan-based Panasonic Corporation and a subsidiary were announced, with Panasonic agreeing to pay $280 million in total. The resolutions related to Panasonic’s U.S.-based subsidiary, Panasonic Avionics Corporation (PAC), and...
FCPA ScorecardDOJ declines to prosecute Dun & Bradstreet, SEC issues $9 million fine for FCPA violations in China
On April 23, Dun & Bradstreet, a commercial data and analytics firm, secured a declination letter from the DOJ regarding FCPA violations stating that, “consistent with the FCPA Corporate Enforcement Policy ,” the DOJ would be declining to bring criminal charges against the company. Dun &...
FCPA ScorecardGuilty plea from former Venezuelan official in bribery scheme
The DOJ announced on Thursday, April 19, that a former Venezuelan official had pleaded guilty to one count of conspiracy to commit money laundering. The charge arose from Cesar David Rincon Godoy’s role in a bribery scheme involving bribes paid by the owners of U.S. companies to Venezuelan...
FCPA ScorecardAruban telecom official pleads guilty to money laundering conspiracy involving FCPA violations
Egbert Yvan Ferdinand Koolman, an official of Servicio di Telecommunicacion di Aruba N.V. (Setar), pleaded guilty to money laundering charges in connection with a scheme to arrange and receive corrupt payments to influence the awarding of contracts in Aruba. The DOJ’s press release describes Setar...
FCPA ScorecardFCPA class action against Embraer dismissed
A class action against Embraer, the Brazilian aerospace firm, was recently dismissed by U.S. District Judge Richard Berman. The class action, which was brought in federal district court in New York, alleged that Embraer had failed to adequately disclose the scope and possible financial impact of...
FCPA ScorecardFormer media executive pleads guilty to bribing UN official
Julia Vivi Wang, a Chinese-born naturalized U.S. citizen, reportedly pleaded guilty this week to violations of the FCPA related to a scheme to bribe the UN General Assembly’s former president John Ashe. Wang is a former executive of a media group that focused on promoting UN development goals, but...
FCPA ScorecardSecond executive pleads guilty to FCPA violations in Siemens case involving bribes in Argentina
On March 15, Eberhard Reichert, a former executive of a Siemens AG subsidiary, pleaded guilty in the U.S. District Court for the Southern District of New York to conspiracy to violate the Foreign Corrupt Practices Act, including conspiracy to commit bribery, falsify corporate books and records,...
FCPA ScorecardKinross Gold Corporation settles SEC FCPA charge
The SEC fined Kinross Gold Corporation $950,000 for its failure to implement and maintain adequate accounting controls at two subsidiaries in Ghana and the Islamic Republic of Mauritania. Kinross neither admitted nor denied the allegations. According to the SEC, Kinross acquired the subsidiaries in...
FCPA ScorecardUK Serious Fraud Office recovers bribe from diplomat from Chad
In what the UK’s Serious Fraud Office (SFO) is calling a first, a £4.4 million recovery from a corruption case will be returned overseas . The SFO prevailed in a trial before the UK High Court and recovered the money from Chadian diplomats, including the wife of the former Deputy Chief of the...
FCPA ScorecardMaryland-based Transport Logistics International Inc. enters deferred prosecution agreement for violations of FCPA antibribery provisions
On March 13, a Maryland federal court unsealed bribery-related charges filed in January 2018 against Transport Logistics International, Inc. (“TLI”), a Maryland-based company which is part of France’s Daher Group, as well as a three-year deferred prosecution agreement filed on March 12. The...
FCPA ScorecardIsraeli real estate conglomerate to pay $500,000 to resolve SEC allegations of FCPA books and records and internal controls violations
On March 9, an Israeli-based real estate conglomerate agreed with the SEC, pursuant to an administrative order , to pay $500,000 to resolve alleged violations of FCPA books and records and internal controls provisions. According to the order, the SEC found that from 2007 through 2012, Elbit Imaging...
FCPA ScorecardSeveral companies report developments in FCPA investigations
In the second half of February, at least three unrelated companies have publicly disclosed the existence and/or status of various FCPA investigations in forms filed with the SEC: Teradata Corporation: On February 23, data analytics company Teradata disclosed that the DOJ and SEC have both declined...
FCPA ScorecardSanofi announces DOJ declination in FCPA investigation
As previously covered , French pharmaceutical company Sanofi S.A. announced in October 2014 that it was investigating whether certain payments made by company employees to healthcare professionals in the Middle East and Africa violated the FCPA. Sanofi launched an investigation to review payments...
FCPA ScorecardHouston-based energy company sues former Venezuelan government officials for bribery related conduct related to Petroleos
On February 16, 2018, Harvest Natural Resources and HNR Energia B.V (collectively, “Harvest”), a Houston-based energy corporation that formally dissolved in May 2017, filed suit in the Southern District of Texas against two former presidents of Venezuela’s national oil company Petroleos de...
FCPA ScorecardDOJ concludes FCPA investigation into Juniper Networks
California-based Juniper Networks, Inc. announced in a February 9 8K filing that the DOJ has concluded its investigation into possible FCPA violations without taking action against the company. The company disclosed the FCPA investigation by the DOJ and the SEC in August 2013, but has not publicly...
FCPA ScorecardDOJ unseals charges against former Venezuelan government officials for money laundering and FCPA violations in Petroleos scheme
On February 12, the DOJ unsealed charges against five former Venezuelan government officials for their involvement in a money laundering scheme at Venezuela’s state-owned energy company Petroleos de Venezuela (Petroleos). The five defendants—Luis Carlos De Leon Perez (De Leon), Nervis Gerardo...
FCPA ScorecardGSK responding to inquiries from SFO, DOJ, and SEC regarding its use of third party advisors in China
In a securities filing on Wednesday, Feb. 7, U.K.-based pharmaceutical company GlaxoSmithKline PLC (“GSK”) announced that it is responding to requests for information from the DOJ and SEC regarding third-party advisors that GSK engaged in China. These requests came about after GSK, pursuant to its...
FCPA ScorecardAllegations by short seller lead to corruption investigation of OSI systems
In a securities filing on Thursday, Feb. 1, California-based OSI Systems, Inc. revealed that the DOJ and SEC have launched investigations into its FCPA compliance and regarding trading by company employees in the OSI Systems securities. These investigations were spurred by a report issued in...
FCPA ScorecardSEC declines enforcement against Cobalt in FCPA investigation for second time
Houston-based Cobalt International Energy, Inc. announced in a January 29, 2018 8-K filing that the SEC had concluded its second investigation relating to the company’s operations in Angola, and that SEC staff did not intend to recommend an enforcement action. The SEC’s investigation began in March...
FCPA ScorecardSFO confirms opening of criminal investigation into aerospace and defense group
On January 18, the Serious Fraud Office (“SFO”) confirmed the opening of an investigation of Chemring Group PLC (“Chemring”) and its subsidiary, Chemring Technology Solutions Limited (“CTSL”) into alleged bribery, corruption, and money laundering. Chemring, a UK-based company that designs and makes...
FCPA Scorecard
Press Releases & Announcements
Buckley Sandler secures $2.632 billion settlement for Universal Entertainment against Wynn Resorts
WASHINGTON, D.C. (March 8, 2018)—Buckley Sandler LLP represented Universal Entertainment Corporation and its subsidiary Aruze USA, Inc. in securing a $2.632 billion settlement that resolves a six-year lawsuit against Wynn Resorts, Limited. The settlement announced today will resolve all claims...
Press ReleasesDavid Krakoff Named a Law360 Trial Ace
Buckley Sandler is proud to announce that partner David Krakoff has been named one of Law360’s 2015 Trial Aces , an honor recognizing the career accomplishments of the top trial attorneys in the U.S. Selected from a pool of more than 200 attorneys, Mr. Krakoff was one of 50 winners for the...
Press ReleasesBuckley Sandler Establishes International Presence With Opening of London Office
WASHINGTON, DC / LONDON, ENGLAND (September 8, 2014) – Buckley Sandler LLP , a leading financial services and criminal & civil enforcement defense law firm, announced today the opening of its first international office, located in London. James T. Parkinson has relocated from the firm’s...
Press ReleasesFormer CEO of Noble Corp., Mark A. Jackson, Resolves SEC Litigation
WASHINGTON, DC (July 3, 2014) - Today, the Securities and Exchange Commission (SEC) agreed to resolve its claims against Mark A. Jackson, the former CEO of Noble Corporation. The SEC had charged Jackson with violating the Foreign Corrupt Practices Act (FCPA) by approving bribes to Nigerian...
Press ReleasesMark Jackson Denies SEC FCPA Allegations; Will Clear His Name in Court
WASHINGTON, DC--(Marketwire - Feb 24, 2012) - David Krakoff , partner with Buckley Sandler LLP , on behalf of his client Mark A. Jackson, former Chief Executive Officer of Noble Corp., responded to the Complaint filed by the Securities and Exchange Commission (SEC) today in Houston. SEC v. Mark...
Press Releases
Our Foreign Corrupt Practices Act & Anti-Corruption Team
Partners
Recent Blog Posts
-
February 15, 2019
OFAC sanctions Iranian entities and individuals supporting intelligence gathering and cyber targeting of U.S. persons
-
February 15, 2019
U.S. Treasury concerned with European Commission's identification of AML/CFT-deficient U.S. territories
-
February 15, 2019
Micronesian official charged with money laundering conspiracy after guilty plea to bribery by Hawaiian executive
-
February 12, 2019
OFAC amends Venezuela-related General Licenses and FAQs on sanctioned oil company
-
February 12, 2019
OFAC designates Turkish individual as “Foreign Sanctions Evader” in relation to settlement resolving alleged Iranian sanctions violations
-
February 8, 2019
Former Petrofac oil-services sales executive pleads guilty in U.K. to bribery charges
-
February 6, 2019
OFAC revises Venezuela-related General Licenses on sanctioned oil company, issues new FAQs
-
February 6, 2019
OFAC reaches settlement with cosmetics company for alleged North Korean sanctions violations
-
February 1, 2019
Former insurance executives charged with laundering bribes to Barbados Minister of Industry
-
February 1, 2019
OFAC announces sanctions against Venezuela’s state-owned oil company; President Trump issues related Executive Order
-
February 1, 2019
OFAC lifts sanctions on designated companies linked to Russian oligarch
-
January 18, 2019
OFAC issues temporary extension of Ukraine-related General Licenses
-
January 11, 2019
Treasury Department sanctions Venezuelan TV mogul over Venezuelan bribery scheme
-
January 9, 2019
OFAC adds illicit foreign exchange operation participants to Specially Designated Nationals List; issues Venezuela-related General License and new FAQ
-
January 4, 2019
Eletrobras reaches settlement of FCPA violations in Brazil
-
January 4, 2019
Polycom reaches settlement of FCPA violations in China
-
December 21, 2018
UK court convicts former Alstom executive
-
December 21, 2018
NY-based financial institution and various individuals charged in Malaysia
-
December 21, 2018
SEC charges former senior executives of Panasonic Avionics
-
December 14, 2018
OECD study finds that government officials punished in only one-fifth of bribery cases
-
December 14, 2018
Former officer of Venezuela oil company pleads guilty to obstruction
-
December 7, 2018
U.S.-based agriculture company discloses investigation
-
December 7, 2018
UK Serious Fraud Office ends first deferred prosecution agreement with Standard Bank
-
November 30, 2018
Buckley Sandler Special Alert: DOJ announces new policy on pursuing individuals in corporate resolutions
-
November 30, 2018
SEC settles with Texas offshore drilling company for violations of FCPA internal controls provision
-
November 30, 2018
Co-conspirators sentenced in Venezuelan bribery scheme involving Venezuelan TV mogul
-
November 30, 2018
SEC releases 2018 report on whistleblower program
-
November 16, 2018
9th Circuit hears oral arguments on overturning FCPA whistleblower retaliation award
-
November 9, 2018
U.S. financial institution acknowledges investigations related to Malaysian development fund scheme
-
November 2, 2018
Oil company executives found guilty in U.K. of money laundering
-
November 2, 2018
U.S. announces charges and guilty plea stemming from Malaysian development fund scheme
-
November 2, 2018
Former PDVSA procurement officer pleads guilty
-
November 2, 2018
Swiss banker sentenced to 10 years related to PDVSA embezzlement and bribery scheme, and PDVSA official pleads guilty in same scheme
-
November 2, 2018
CEO of Haitian development & reconstruction company charged in bribery scheme
-
October 19, 2018
DOJ issues new guidance regarding corporate monitors
-
October 11, 2018
Interpol chief detained in China on bribery allegations
-
October 11, 2018
SEC enforcement director gives remarks on FCPA compliance
-
October 5, 2018
DOJ provides further guidance on FCPA Corporate Enforcement Policy in speech
-
October 5, 2018
DOJ reportedly investigating Major League Baseball for potential FCPA violations
-
October 5, 2018
SBM CEO and executive sentenced to prison for conspiracy to bribe foreign officials
-
October 5, 2018
SEC settles FCPA accounting violations with Stryker
-
September 28, 2018
Petrobras settles FCPA violations for $853 million to U.S. and Brazil
-
September 28, 2018
SEC settles FCPA charges with former CEO of Chilean mining company
-
September 21, 2018
Class certification granted to hedge fund investors
-
September 18, 2018
Financial advisor pleads guilty to money laundering in PetroEcuador case
-
September 18, 2018
United Technologies settles FCPA charges with SEC
-
September 18, 2018
DOJ secures additional guilty pleas in wide-ranging PDVSA case
-
September 7, 2018
Real estate broker and nephew of former UN Secretary-General sentenced for trying to bribe a foreign official
-
September 7, 2018
ING settles corrupt practices case in the Netherlands for approximately $900 million and receives SEC declination
-
September 7, 2018
Ensco receives double declination in FCPA investigation
-
September 7, 2018
Sanofi settles FCPA action with SEC for $25.2 million
-
August 31, 2018
2nd Circuit rules that FCPA does not reach foreign individuals without their own ties to U.S.
-
August 31, 2018
Second Circuit rules that FCPA does not reach foreign individuals without their own ties to U.S.
-
August 31, 2018
SEC issues administrative order against U.S.-based global investment management firm
-
August 31, 2018
Barbadian insurance company receives first declination with disgorgement under FCPA corporate enforcement policy
-
August 31, 2018
Global technology company confirms U.S. investigations into Hungarian sales operations
-
August 30, 2018
Barbadian insurance company receives first declination with disgorgement under FCPA Corporate Enforcement Policy
-
August 30, 2018
SEC issues administrative order against investment manager Legg Mason
-
August 30, 2018
Microsoft confirms U.S. investigations into Hungarian sales operations
-
August 29, 2018
Global bank settles two FCPA actions for $10.5 million
-
August 24, 2018
UK SFO charges former Güralp Systems employees with bribery conspiracy as DOJ declines to prosecute the company for FCPA violations
-
August 17, 2018
Colombia’s former anti-corruption chief pleads guilty to money laundering conspiracy related to foreign bribes
-
August 10, 2018
Former Malaysia Prime Minister charged with money laundering
-
August 10, 2018
Former Barbadian Minister of Industry charged with money laundering
-
August 3, 2018
Another executive arrested in PDVSA bribery case
-
July 20, 2018
Court dismisses SEC allegations against executives of hedge fund management firm as time-barred
-
July 20, 2018
Latest conviction in PDVSA bribery case
-
July 6, 2018
Global bank pays $76.7 million to settle hiring practices case
-
July 6, 2018
SEC settles with Beam Suntory for $8.2 million regarding India payments
-
June 29, 2018
Aruban telecom official sentenced for money laundering conspiracy involving FCPA violations
-
June 27, 2018
Non-profit advocacy organizations accuses Bank of England of deceptive report on US whistleblower tip rewards programs
-
June 15, 2018
Global bank settles FCPA allegations concerning “sons and daughters” investigation into hiring practices
-
June 8, 2018
Legg Mason settles FCPA allegations with DOJ
-
June 8, 2018
Société Générale settles FCPA allegations concerning bribery of Libyan officials
-
June 1, 2018
Legg Mason preparing for FCPA settlement
-
May 18, 2018
Macau real estate developer sentenced for bribing UN officials
-
May 11, 2018
Brother of Honduran government official indicted for laundering bribes in New Orleans
-
May 11, 2018
DOJ issues new policy against “piling on” in corporate enforcement, FCPA cases
-
May 4, 2018
Clear Channel Outdoor discloses potential FCPA violations
-
May 4, 2018
Panasonic settles parallel FCPA actions for $280 million
-
April 27, 2018
DOJ declines to prosecute Dun & Bradstreet, SEC issues $9 million fine for FCPA violations in China
-
April 27, 2018
Guilty plea from former Venezuelan official in bribery scheme
-
April 20, 2018
Aruban telecom official pleads guilty to money laundering conspiracy involving FCPA violations
-
April 10, 2018
FCPA class action against Embraer dismissed
-
April 10, 2018
Former media executive pleads guilty to bribing UN official
-
March 30, 2018
Second executive pleads guilty to FCPA violations in Siemens case involving bribes in Argentina
-
March 30, 2018
Kinross Gold Corporation settles SEC FCPA charge
-
March 30, 2018
UK Serious Fraud Office recovers bribe from diplomat from Chad
-
March 16, 2018
Maryland-based Transport Logistics International Inc. enters deferred prosecution agreement for violations of FCPA antibribery provisions
-
March 16, 2018
Israeli real estate conglomerate to pay $500,000 to resolve SEC allegations of FCPA books and records and internal controls violations
-
March 14, 2018
Several companies report developments in FCPA investigations
-
March 14, 2018
Sanofi announces DOJ declination in FCPA investigation
-
February 28, 2018
Houston-based energy company sues former Venezuelan government officials for bribery related conduct related to Petroleos
-
February 16, 2018
DOJ concludes FCPA investigation into Juniper Networks
-
February 16, 2018
DOJ unseals charges against former Venezuelan government officials for money laundering and FCPA violations in Petroleos scheme
-
February 9, 2018
GSK responding to inquiries from SFO, DOJ, and SEC regarding its use of third party advisors in China
-
February 9, 2018
Allegations by short seller lead to corruption investigation of OSI systems
-
February 2, 2018
SEC declines enforcement against Cobalt in FCPA investigation for second time
-
January 26, 2018
SFO confirms opening of criminal investigation into aerospace and defense group
-
January 19, 2018
Criminal charges unsealed against former executive of hedge fund manager