Previous posts have highlighted FCPA enforcement actions concerning conduct (in whole or in part) Greece, Georgia and Ukraine, and Poland.
This post highlights FCPA enforcement actions concerning conduct (in whole or in part) in the following countries:
In November 2024, the SEC announced a Foreign Corrupt Practices Act enforcement action against Cyril Sebastien Dominique Cabanes (“Cabanes”) – a French citizen and resident of Singapore who was previously a member of the board of directors of Azure
In recent months, I’ve had several exchanges with various individuals (including journalists) about FCPA enforcement and the false narrative that FCPA enforcement has stopped.
When shown clear evidence that the narrative is indeed false, two common responses have been:
(1)
As highlighted in this prior post, in 2012 BizJet International Sales and Support Inc. (a Tulsa, OK based provider of aircraft maintenance, repair and overhaul services) resolved an $11.8 million FCPA enforcement action “for bribing government officials in Latin
Recently, I had some back and forth exchanges on LinkedIn with John Reed Stark (a former SEC enforcement attorney) on SEC FCPA enforcement.
An overview of the points I raised are set forth below.
Often when there is a discussion
In August, Asante Berko (a former Executive Director of Goldman Sachs International) was convicted by a jury of FCPA and related offenses in connection with a Ghana bribery scheme after a trial in the E.D. of New York.
Thereafter, Berko
This post highlights nine Foreign Corrupt Practices Act enforcement actions concerning conduct (in whole or in part) in Greece.
Novartis (2020)
The enforcement action concerned conduct in Greece, Vietnam and South Korea.
As to Greece, the allegations were: “Novartis Greece,
This post highlights FCPA enforcement actions concerning conduct (in whole or in part) in Georgia and Ukraine.
Georgia
Linde (2017)
The enforcement action concerned conduct in Georgia and the allegations were: “From approximately November 2006 to December 2009, Linde, through
This post highlights 8 FCPA enforcement actions concerning conduct (in whole or in part) in Poland.
Hewlett-Packard (2014)
The enforcement action concerned conduct in Russia, Poland and Mexico.
As to Poland, the allegations were: HP Poland “(i) caused the falsification
In 2019, Alvaro Pulido Vargas was criminally charged with laundering the proceeds of violations of the FCPA in connection with a scheme to pay bribes to take advantage of Venezuela’s government controlled-exchange rate. (See here).
In 2021, the DOJ
