Tagged: bribery

Former Ericsson Employee Indicted for Role in Foreign Bribery Scheme

In a surprising (but fully warranted) twist, the Justice Department returned an indictment against a former employee of Telefonaktiebolaget LM Ericsson (“Ericsson”), a global telecommunications company, for his role in paying approximately $2.1 million in bribes to high-level government officials in the Republic of Djibouti. Afework “Affe” Bereket, 53, a dual citizen of Ethiopia and Sweden, was charged in a two-count indictment – Count 1...

Insights from Recent NAVEX Global and KPMG Surveys

Chief compliance officers are always hungry for benchmarking data, for comparisons and insights around how their respective compliance programs stack up against other companies, especially in the same industry.  Compliance professionals, as a general rule, are collaborative and willing to share information with each other.  CCOs are an optimistic lot and enjoy sharing best practices, ideas and insights in order to further the ethics and...

Webinar: Monitoring Your Third Parties — Digging into Distributor and Agent Risks

Webinar: Monitoring Your Third Parties — Digging into Distributor and Agent Risks December 15, 2020, 12 Noon EST Sign Up HERE Government enforcement actions against companies for anti-corruption, sanctions, money laundering and accounting misconduct often focus on third-party risks. And for good reason — government enforcement actions almost always cite third-party misconduct and complicity in illegal schemes to pay bribes, circumvent sanctions and launder money....

Goldman Sachs Settles Massive 1MDB Bribery Case and Agrees to Pay Nearly $3 Billion (Part I of III)

The Justice Department finally closed out its investigation of Goldman Sachs’ massive bribery scheme involving Malaysia’s 1MDB fund.  The case is now the largest in US FCPA history (based on its payment to DOJ and related US agencies).  Goldman Sachs entered into  three-year deferred prosecution agreement (“DPA”) with the filing of a criminal information charging conspiracy to violate the anti-bribery provisions of the FCPA.  At...

Episode 157 — A Review of World Acceptance Corp. Settlement with SEC for FCPA Violations

World Acceptance Corporation (“WAC”), a US-based consumer loan company, agreed to pay the SEC $21.7 million for FCPA violations in Mexico.  WAC’s cited violations covered the full gamut of FCPA violations, including bribery payments to government officials in Mexico, failure to keep accurate books and records and inadequate internal accounting controls. In this Episode, Michael Volkov discusses the WAC SEC settlement.

Episode 141 — Practical Approaches to Managing Beneficial Ownership Risks (Part II of II)

In a two-part series, Michael Volkov examines the continuing problem of identifying and mitigating beneficial ownership risks.  Money launderers and corrupt individuals continue to rely on corporate structures to disguise their ownership interests to further illicit schemes.  Companies have to develop strategies that practically address the risks without dedicating disproportionate resources to the problem. In the first episode, Michael Volkov discusses beneficial ownership risks and...

Corrupt Intent and Bribery

In my showcase of profound but obvious points, let me add to my collection – an illegal bribe often turns on the actor’s state of mind.  Did he or she act with corrupt intent? The actor’s state of mind is a common element to many criminal offenses.  In most cases, the government has strong evidence of such corrupt intent.  In some cases, the government is...

DOJ Sweeps Up Two More Defendants in PDVSA Criminal Investigation

The Justice Department’s sprawling and successful prosecution of bribery and money laundering surrounding PDVSA, Venezuela’s state-owned energy company, shows no signs of letting up.  DOJ’s prosecutions began in 2015, and with the recent announcement of two new defendants, DOJ’s scorecard has reached a total of 21 defendants, 15 of whom have pleaded guilty.  Given PDVSA’s reputation for corruption, which is well earned (or as I...

DOJ Arrests Micronesian Official and Hawaii-Based Businessman Pleads Guilty to FCPA Violation

In January 2019, the Justice Department brought an interesting FCPA prosecution involving a Hawaii-based businessman, Frank James Lyon, and Master Halbert, a government official from Micronesia.  DOJ’s prosecution was interesting for two significant reasons – first, it was another example of DOJ enforcement efforts against the payor of the bribe for violating the FCPA and the recipient of the bribe, the foreign official, for money...

DOJ Issues Declination and Disgorgement Under FCPA Corporate Enforcement Policy

In a recently released letter (here), the Justice Department issued a declination to the Insurance Corporation of Barbados Limited (ICBL) for violations of the FCPA under the FCPA Corporate Enforcement Policy.  DOJ required ICBL to pay approximately $93,000 in disgorgement. ICBL paid approximately $36,000 in bribes to Donville Innis, a Barbadian government official, in exchange for government contracts worth approximately $686,000 and $93,000 in profits....