DOJ and SEC Archives - Corruption, Crime & Compliance

18 Sep, 2023

Episode 290 — Deep Dive into DOJ’s and SEC’s Corficocolombiana FCPA Settlement

The Department of Justice has been relatively quiet this year in announcing corporate FCPA enforcement actions and settlements. Aside from the Ericsson breach of its Deferred Prosecution Agreement, the Corficocolombiana (“Corfico”) and Grupo Aval settlement is the first in 2023 involving a corporate FCPA resolution. For the SEC, the Corfico and Grupo Aval settlement is the sixth corporate resolution in 2023. Corfico and its parent...

General

20 Sep, 2022

GOL’s Bribery Schemes Orchestrated by Board Director (Part II of II)

GOL’s bribery schemes present some interesting lessons. Interestingly, at the center of the bribery scheme was a member of GOL’s board of directors. The bribery scheme was motivated by potential legislation that would benefit GOL and other Brazilian airlines. In 2011, Brazil proposed an economic stimulus consisting, in part, with reduced payroll taxes for labor-intensive industries. To support this reduction, GOL’s director agreed to pay...

General

20 Sep, 2022

DOJ and SEC Secure $41 Million Settlement from Brazilian Airline for FCPA Violations (Part I of II)

The Department of Justice and the Securities and Exchange Commission reached a $41 million settlement with GOL Linhas Aéreas Inteligentes S.A. (“GOL”) to resolve criminal and civil foreign bribery charges. GOL entered into a three-year deferred prosecution agreement (“DPA”) with DOJ in exchange for payment of a $17 million criminal penalty. DOJ credited $1.7 million of that penalty against a $3.4 million fine that GOL...

General

12 Mar, 2017

FCPA Pilot Program Motors On

No one was really surprised when Kenneth Blanco, Acting Assistant Attorney General for the Criminal Division, US Department of Justice, announced last week that DOJ was planning to continue the FCPA Pilot Program past April 5, 2017, the scheduled expiration date. Blanco stated in a speech given at the annual White Collar Crime Conference: Before I conclude, I would be remiss if I did not...