The Sweden-based telecommunications company, Ericsson, agreed to a pay a total of $1 billion (yes, billion with a “B”) for FCPA violations. Ericsson entered into settlement agreements with DOJ and the SEC. Ericsson agreed to pay a criminal penalty of over $520 million and approximately $540 million to the SEC. An Ericsson subsidiary in Egypt entered a guilty plea to an FCPA conspiracy to violate...
Recently, the Justice Department unsealed an indictment charging Jose Carlos Grubisich, the former CEO of Braskem S.A. with participating in an FCPA conspiracy with Odebrecht S.A. Grubisisch was arrested last Wednesday. Copy Here. Grubisich is charged with one count of conspiracy to violate the FCPA bribery provisions, one count of FCPA conspiracy to violate the FCPA’s books and records provisions and falsely certifying financial reports,...
Apollo Aviation Group, now Carlyle Aviation Partners, agreed to pay OFAC $210,600 for 12 violations of the Sudanese Sanctions Program. Carlyle acquired Apollo in December 2018, and Carlyle was not involved in the transactions. The broad prohibition in the Sudanese Sanctions Program were lifted on January 17, 2017, but the transactions occurred prior to the relaxation of the sanctions program. Apollo was a multi-strategy aviation...
The Department of Justice recently announced updates to its Foreign Corrupt Practices Act Corporate Enforcement Policy. While the changes were relatively minor, the modifications underscored important principles surrounding the FCPA Corporate Enforcement Policy. There is no question that DOJ has landed on a Corporate Enforcement Policy that took years to develop. The FCPA Corporate Enforcement Policy now applies to all corporate criminal prosecutions except Antirust...
Even the mighty can fall – Apple agreed to pay OFAC $467k for violations of the Foreign Narcotics Kingpin Sanctions regulations. In 2008, Apple entered into an applications development agreement with SIS, a Slovenian company. SIS and its director and majority owner, Savo Stjepanovic, were designated under the Foreign Narcotics Kingpin Designation Act and added to the Specially Designated Nationals List (“SDN List”). Apple’s screening...
Thanksgiving is a moment to celebrate gratitude. For the Volkov Law Group, we are grateful for our clients, friends and colleagues. We want to say a big “thank you” to all of our clients for trusting us with your important legal matters; to all of our readers who help make our blog a success; and to all of our colleagues who refer clients, engage in webcasts and presentations with us, and generally...
The Volkov Law Group — Michael Volkov, Matt Stankiewicz, Jessica Sanderson and Stephen Cheng — was honored to represent Lt. Col. Alexander Vindman in the House Impeachment Inquiry. Lt. Col. Vindman testified before the House Intelligence Committee on Tuesday, November 19. A video of the testimony is available here. A video of highlights is here. Stephen Colbert’s review is here. A copy of Lt. Col....
The Justice Department won another FCPA trial. After a three-week trial, Mark Lambert of Mount Airy, Maryland, was found guilty of four counts of violating the FCPA, two counts of wire fraud and one count of conspiracy to violate the FCPA and wire fraud. Lambert is scheduled to be sentenced on March 9, 2020. In 2018, Transport Logistics International, a Maryland company, entered into a...
Bureau van Dijk, a Moodys Analytics Company, recently released a new white paper, What you need to know about sanctions compliance. You can download the white paper here. I was pleased to contribute to the white paper and hope you find it helpful.
Samsung’s recent FCPA settlement with the Justice Department capped yet another example of a company involved in bribing Petrobas in Brazil for valuable contracts. The scope of the bribery scheme was focused on a contingent deal involving Samsung’s desire to build a drillship for Chartering Company in Houston, Texas. Beginning in 2007 and continuing until 2013, Samsung conspired with others to violate the FCPA by...
