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This is a very complicated case, Maude. You know, a lotta ins, a lotta outs, a lotta what-have-yous. And, uh, a lotta strands to keep in my head, man. Lotta strands in old Duder's head. – The Dude, The Big Lebowski Each FCPA case provides valuable lessons
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Talk about a reminder of the past, Asante Berko, a former Executive Director in Goldman Sachs, recently was arrested in London on criminal FCPA charges arising from his involvement in a bribery scheme in Ghana. The surprising part of the case was the delay in his arrest – over 2 years.
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GOL's bribery schemes present some interesting lessons. Interestingly, at the center of the bribery scheme was a member of GOL's board of directors. The bribery scheme was motivated by potential legislation that would benefit GOL and other Brazilian airlines. In 2011, Brazil proposed an economic stimulus
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The Justice Department announced the indictment in New York of Cary Yan, a Chinese entrepreneur, and Gina Zhou, his assistant, on FCPA and money laundering charges relating to a scheme to secure control of an atoll owned by the Republic of the Marshall Islands (RMI). Yan and Zhou paid bribes
Podcasts
The Second Circuit Court of Appeals affirmed the district judge's post-conviction dismissal of FCPA counts against Lawrence Hoskins, a former Alston executive, for his involvement in bribery scheme to secure a $118 million energy contract in Indonesia. The Hoskins FCPA case has had a long and tortious
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CCOs, by definition, are careful and deliberate. It comes with the profession. As risk managers, CCOs are skilled in identifying, assessing and acting in a risk environment. The impact of the new CCO certification requirement, however, presents serious risks that cannot be brushed off or ignored in the face of
Podcasts
In following the Justice Department and the Securities Exchange Commission FCPA enforcement actions, I am always reminded of the popular phrase — “reading the tea leaves.” (or “tasseography,” a fortune-telling method based on tea leave patterns in tea sediments). Despite a slow initial year in 2021, the Biden Administration’s
Podcasts
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 resolve FCPA violations that occurred in Brazil. The US Department of Justice closed
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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 exchange for contracts for coke and chemicals with Al Nasr, an Egyptian state-owned company. Last year,
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Choose to be optimistic. It feels better.” – Dalai Lama Forgive me for my optimism. It is the only way to live a meaningful life. Or as some would say – being a pessimist is too much of a burden. We begin a New Year -- and I am optimistic. To turn the
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While we wait for the coming FCPA enforcement storm, DOJ and the SEC have quietly continued to rack up and resolve several enforcement actions. Here is short and sweet review of many of these actions: Luis Enrique Martinelli, son of the former Panama President, was recently presented in federal court
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We have heard it over and over, again and again – third-parties pose significant risks of bribery for all global businesses. Almost every FCPA enforcement action includes some form of third-party misconduct. The current picture from the Stanford FCPA Resource confirms the story. A cottage industry of automated platforms,