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By: FCPA Professor LLC

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Mike Koehler

Latest from FCPA Professor

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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.”…
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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…
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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…
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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…
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As highlighted in this prior post, in November 2018 the DOJ criminally charged former Goldman Sachs executives Tim Leissner and Ng Chong Hwa (Roger Ng) (along with Low Taek Jho – Jho Low) with Foreign Corrupt Practices Act offenses for paying bribes to various Malaysian and Abu Dhabi officials in connection with 1Malaysia Development Berhad (1MDB), Malaysia’s state-owned and state-controlled investment development company. Leissner pleaded guilty and in October Goldman Sachs resolved a net $1.66 …
Tired of reading about the Foreign Corrupt Practices Act? Well, sometimes I get tired writing about the FCPA. Thus, today’s post is this link to a recent episode of the In-House Warrior podcast. During the podcast, I speak to Richard Levick about the following FCPA topics: how compliance professionals need to gain comfort with FCPA uncertainty; FCPA enforcement during a Biden administration; whether the FCPA has been successful in achieving its objectives; what the “b” word (bribery) means; and how…
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The FCPA Flash podcast provides in an audio format the same fresh, candid, and informed commentary about the Foreign Corrupt Practices Act and related topics as readers have come to expect from written posts on FCPA Professor. This FCPA Flash episode is a conversation with Moe Fodeman (who along with colleagues at Wilson Sonsini) successfully represented certain investors who were deemed “victims” of Och-Ziff’s bribery and secured a $138 million restitution order under the Mandatory Victims…
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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. As discussed in this post, SEC Commissioners Hester Peirce and Elad Roisman hit an internal controls homerun in a recent statement explaining why they voted against an SEC settled action. A potpourri of FCPA and…
Dr. Reddy’s Laboratories Ltd., an India-based pharmaceutical company with ADRs listed on the New York Stock Exchange recently disclosed that it “has commenced a detailed investigation into an anonymous complaint.” According to this filing: “The complaint alleges that healthcare professionals in Ukraine and potentially in other countries were provided with improper benefits in violation of U.S. laws. The investigation is being carried out by a reputed independent U.S. law firm.” The post Indian …
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The Dodd-Frank Act enacted in July 2010 contained whistleblower provisions applicable to all securities law violations including those under the Foreign Corrupt Practices Act. In this prior post from July 2010, I predicted that the whistleblower provisions would have a negligible impact on FCPA enforcement. As noted in this prior post, my prediction was an outlier (so it seemed) compared to the flurry of law firm client alerts predicting that the whistleblower provisions would…