Tagged: FCPA

14 Apr, 2024

Episode 317 — Deep Dive into Trafigura’s FCPA Settlement

On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ’s FCPA Sweep against the industry. Trafigura joined the list of international commodity trading companies to suffer FCPA enforcement actions — Vitol, Sargeant Marine, Glencore, Freepoint, and Gunvor. DOJ’s corporate resolutions are connected to individual prosecutions and guilty pleas of...

General

8 Apr, 2024

Trafigura Joins the FCPA Enforcement Club: Pleads Guilty and Pays Over $126 Million for Bribery Violations in Brazil (Part I of III)

General

2 Apr, 2024

DOJ Enters Whistleblower Sweepstakes — Plans to Implement Bounty Program (Part I of II)

The Securities and Exchange Commission has gained well-publicized traction through its formal whistleblower bounty program. Only a small portion of these whistleblower reports involve FCPA, anti-bribery allegations. Notwithstanding this fact, the SEC whistleblower program has been an unquestioned success. Given this example, it is not surprising that the Department of Justice recently announced its plan to create its own whistleblower bounty program. In a recent...

Podcasts

24 Mar, 2024

Episode 314 — A Deep Dive into DOJ’s Gunvor FCPA Enforcement Action

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 a deferred or non-prosecution agreement. Instead, DOJ required Gunvor to plead guilty to one count of FCPA conspiracy. Gunvor entered into a...

General

20 Mar, 2024

Gunvor’s Blockbuster FCPA Settlement: Lessons Learned and Trends (Part III of III)

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 particular), DOJ’s Gunvor settlement of $661 million stands as the ninth largest FCPA settlement in history. DOJ’s settlement is proportionate to the misconduct and...

General

19 Mar, 2024

Gunvor’s Bribery Schemes — Third-Parties, Shell Companies and Evasion of Controls (Part II of III)

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 — large and valuable energy products (oil, gas etc.) are controlled by foreign-owned companies. All of these...

General

18 Mar, 2024

Gunvor Falls Under FCPA Axe and Agrees to Pay Criminal Penalty of $661 Million (Part I of III)

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 is one of the world’s largest commodities trading companies. DOJ’s settlement represents a “return” to its long-standing...

General

15 Mar, 2024

Former Stericyle Official Charged in Foreign Bribery Scheme

According to the terms of a superseding information made public by the U.S. Attorney’s Office for the Southern District of New York on or about February 13, 2024, Mauricio Gomez Baez (“Baez”)—a former Stericycle executive for Latin America—was officially charged with a single count of conspiracy for his role in a multi-year scheme to expand Stericycle’s business opportunities in the Latin American region (particularly, Mexico,...

General

13 Mar, 2024

Ex-Vitol Oil & Gas Trader Convicted of Bribing Foreign Officials

Following an 8 week trial, a federal jury in Brooklyn has convicted Javier Aguilar on charges relating to the former Vitol trader’s violations of the Foreign Corrupt Practices Act. He faces up to 30 years in prison. Aguilar bribed officials in Mexico and Ecuador to obtain contracts from their state-owned oil companies. He was also convicted of using a complex money laundering scheme to avoid...

Podcasts

3 Mar, 2024

Episode 311: Tom Fox on FCPA Enforcement — DOJ’s Approach to Recidivism and Self-Disclosure

In this special episode of Corruption, Crime, and Compliance, Michael Volkov joins colleague and long-time friend Tom Fox as they delve into the intricacies of recent FCPA enforcement actions, shedding light on the evolving landscape of corporate compliance. From the ABB case to the SAP settlement, Michael and Tom dissect the nuances of voluntary disclosure, extensive remediation, and the shifting priorities of the Department of...

Tagged: FCPA

Episode 317 — Deep Dive into Trafigura’s FCPA Settlement

Trafigura Joins the FCPA Enforcement Club: Pleads Guilty and Pays Over $126 Million for Bribery Violations in Brazil (Part I of III)

DOJ Enters Whistleblower Sweepstakes — Plans to Implement Bounty Program (Part I of II)

Episode 314 — A Deep Dive into DOJ’s Gunvor FCPA Enforcement Action

Gunvor’s Blockbuster FCPA Settlement: Lessons Learned and Trends (Part III of III)

Gunvor’s Bribery Schemes — Third-Parties, Shell Companies and Evasion of Controls (Part II of III)

Gunvor Falls Under FCPA Axe and Agrees to Pay Criminal Penalty of $661 Million (Part I of III)

Former Stericyle Official Charged in Foreign Bribery Scheme

Ex-Vitol Oil & Gas Trader Convicted of Bribing Foreign Officials

Episode 311: Tom Fox on FCPA Enforcement — DOJ’s Approach to Recidivism and Self-Disclosure

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