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In February 2023, the DOJ announced that Glenn Oztemel (previously employed by Freepoint Commodities LLC) and Eduardo Innecco (an agent for the company) were charged with FCPA and related offenses for an alleged Brazil bribery scheme. (See here for the prior

“What is an internal accounting controls violation? Anything that the SEC staff thinks—and three out of five Commissioners agree—is a righteous case and to which a public company is willing to settle.”
A good read here from Walker Newell (Woodruff