In following the Justice Department and the Securities Exchange Commission FCPA enforcement actions, I am always reminded of the popular phrase — “reading the tea leaves.” (or “tasseography,” a fortune-telling method based on tea leave patterns in tea sediments). Despite a slow initial year in 2021, the Biden Administration’s stamp and push on FCPA enforcement is becoming clear. Keep in mind, DOJ and SEC officials...
The Justice Department has been promising a new, more aggressive approach to FCPA enforcement. DOJ officials have made statements to that effect on numerous occasions. The Biden Administration touted its elevation of the battle against corruption as a national security issue and it issued its Strategy Against Corruption, which included numerous promises, initiatives and proposed policy changes. Along with these events, DOJ has repeatedly touted...
In a long-anticipated and major enforcement action, the Justice Department and the Commodities and Futures Trading Commission resolved a sprawling investigation with Glencore International A.G. and Glencore Ltd, a Swiss-based commodity trading and mining company. Glencore entered guilty pleas for FCPA violations and a commodity price manipulation scheme. Glencore paid over $1.1 billion to resolve these two major investigations. The resolution in the U.S. was part of...
