I have found over my 23 years of law practice that, assuming I’ve consumed my usual copious amount of coffee, I can be quite productive and efficient when I get into a flow. When that flow is interrupted – by a phone call, someone popping into my office for a quick question, a car alarm going off, etc. – it can be difficult to get back into the groove. The good news is that a…
In August 2020, the DOJ announced that Jose Luis De Jongh Atencio (De Jongh) “a former official at Citgo Petroleum Corporation, a Houston-based subsidiary of Venezuela’s state-owned and state-controlled energy company Petróleos de Venezuela S.A. (PDVSA)” was criminally charged “for his alleged role in laundering the proceeds of a scheme involving bribes made to corruptly secure business advantages from Citgo and PDVSA.” In the indictment, the DOJ alleges that De Jongh was a “foreign official.”…
FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.” Set forth below are the topics discussed this week on FCPA Professor. This FCPA Flash podcast episode is a conversation with the lawyer who successfully represented “victims” of Och-Ziff’s bribery scheme – resulting in a $138 million restitution award for his clients. For your listening enjoyment here
Small Investors Beware When investors only lose around $1.1 million, and the person perpetrating the fraud is enriched $400,000, the story generally won’t make headlines. We’re not sure what dollar amount is significant to the news media, but the Sneed case is illustrative of how ordinary investors get scammed. Digital Asset Mining Pools Clifton Curtis Sneed, aka Kaison Sneed, is being sued by the SEC in North Texas. Sneed established a company, The Trade Group…
Recently Acting Assistant Attorney General Brian Rabbitt delivered this virtual speech to a White Collar Crime workshop. As excerpted below, Rabbitt touched upon a variety of white-collar crime topics including individual accountability, DOJ policy, and data analytics. Regarding white-collar crime generally, Rabbitt stated: “[W]hite-collar crime comes in a variety of forms.  Our experience has shown us that corporate criminal activity is increasingly sophisticated and also increasingly global.  Because of this, the Criminal Division has in…
I hope this Thanksgiving finds you being thankful for many things in your life. Among the many things I am thankful for are your readership and I hope FCPA Professor elevates your FCPA knowledge and skills. May your turkey be golden brown. The following FCPA enforcement actions have involved, in whole or in part, alleged improper conduct in Turkey. Alexion Pharmaceuticals (2020) In July 2020, the company resolved a $21.5 million SEC FCPA enforcement action based…