Tagged: DOJ FCPA

Episode 82 — A Deep Dive into the Cognizant Technology FCPA Enforcement Action

In the first corporate FCPA action of 2019, Cognizant Technology Solutions Company settled its long-running FCPA case, agreeing to pay the SEC $25 million.  At the same time, the Justice Department announced: (1) its’ declination under the FCPA Corporate Enforcement Policy; and (2) the indictment of Cognizant’s former President and General Counsel for criminal FCPA violations. In this Episode, Michael Volkov discusses the Cognizant FCPA...

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...

Las Vegas Sands Suffers Double Whammy and Resolves FCPA Action with DOJ for $7 Million

Following a separate SEC action (here), the Justice Department resolved FCPA charges against Las Vegas Sands for $7 million. DOJ and Las Vegas Sands entered into a non-prosecution agreement (NPA) citing much of the same evidence outlined by the SEC in its enforcement action against Las Vegas Sands for $9 million. The Justice Department’s NPA includes a statement of facts centering on large payments made...

Serious Fraud Office Makes Big Splash with UK Bribery Act Resolution with Rolls Royce

After years of fits and starts, and promises and disappointments, the Serious Fraud Office and the UK Bribery Act made its initial splash on the anti-corruption enforcement landscape. Since 2011, companies have been warned that the SFO would begin enforcing the UK Bribery Act. There have been a few enforcement actions and important legal modifications in the UK authorizing deferred prosecution agreements. While it has...