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In a recent blockbuster FCPA settlement, DOJ announced a $661 million resolution with Gunvor, one of the world's largest commodities trading companies. DOJ's settlement represents a "return" to its long-standing aggressive approach to FCPA enforcement. DOJ did not permit Gunvor to enter into
General
The Department of Justice's blockbuster FCPA settlement with Gunvor restores the credibility of DOJ's pronouncements of DOJ's commitment to aggressive FCPA enforcement. While I have questioned DOJ's commitment to its corporate enforcement policy in recent high-profile settlements (ABB and SAP, in
General
Gunvor's bribery scheme is not very surprising nor ingenious. After all, a number of energy trading companies have been prosecuted for bribery over the years, including Glencore, Vitol, Freepoint. Numerous individuals have been prosecuted, convicted and some have cooperated. The global energy trading market presents numerous risk factors
General
You have to give the Justice Department credit -- after two slow enforcement years, DOJ is starting off 2024 with a relative "bang;" first, DOJ reached a large settlement with SAP in January, and now, DOJ has reached a blockbuster settlement with Gunvor S.A. for $661 million. Gunvor
General
Raymond Kohut, a 68-year old Canadian citizen, a former employee of Swiss commodities trader, Gunvor Group, Ltd., pleaded guilty to paying $22 million in bribes to Ecuadoran government officials at state-owned oil company, PetroEcuador. Kohut pleaded guilty to one count of money laundering conspiracy before a federal judge