Tagged: Brazil Bribery

WPP, the Largest Global Advertising Group, Settles FCPA Charges with SEC for $19.2 Million (Part I of III)

After a long hiatus, the SEC announced a settlement with WPP plc, the world’s largest advertising group, for FCPA violations in India, China, Brazil and Peru for $19.2 million.  The SEC’s resolution charges WPP with violations of the anti-bribery, books and records and internal accounting controls provisions of the FCPA. The Justice Department’s investigation of WPP appears to be ongoing. WPP has dual headquarters, in...

DOJ FCPA Settlement: J&F Investimentos’ Bribery Schemes (Part II of V)

J&F’s Investimentos bribery scheme was pervasive and was coordinated with a senior Brazilian Finance minister and orchestrated through the use of United States banking.  The Brazilian official appears to be Guido Mantega, who went on to serve as Brazil’s finance minister. Given J&F’s large penalty in Brazil, DOJ’s resolution was reasonable in light of the consistent use of the US banking system to execute the...