Tagged: Petrobras

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10 Apr, 2024

Lessons-Learned from the Trafigura FCPA Settlement (Part III of III)

The Justice Department is rightly trumpeting its successful sweep of the commodities trading industry. DOJ’s success is reflected in its six separate corporate resolutions and 20 individual convictions, resulting in over $1.7 billion in penalties. Companies in the global commodities trading industry should take heed of DOJ’s focus. Every significant player in the industry, if not under investigation, should audit and review their operations. Those...

General

9 Apr, 2024

Trafigura’s Bribery Scheme: Clandestine Meetings, 3rd Parties and Shell Companies (Part II of III)

Trafigura’s bribery scheme resembles the same schemes implemented by its significant competitors — Vitol, Glencore, Gunvor. At the core of the conduct, Petrobras and Brazilian government officials collected bribes in exchange for valuable contracts for Petrobras oil. The factual statement reflects DOJ’s extensive knowledge base in the international commodity trading industry — DOJ had access to several significant cooperating witnesses, including Petrobras officials and trader...

General

28 Feb, 2024

DOJ’s FCPA Enforcement Focus on Central and Latin America

When it comes to FCPA enforcement, the Justice Department’s global focus for many years was on Asian countries, and in particular, China. This trend, however, has continued, but in the past few years, DOJ has brought a larger percentage of criminal cases against Central and Latin American entities and individuals. The reason for this focus reflects DOJ’s long-standing and closer working relationships with prosecutors and...

General

12 Jan, 2024

Freepoint FCPA Settlement: Incendiary Mix of Commodities Trading and Third-Party Risks (Part II of II)

Perhaps it is fitting to end this unusual FCPA enforcement year with another in a series of compliance reminders — the quickest way to experience a bribery scandal is to ignore third-party risks. This has been a continuing theme this year and Freepoint is yet another example of why managing third-party risks is so important to any anti-bribery compliance program. The relevant facts underlying the...

General

20 Feb, 2023

DOJ Charges Two Oil and Gas Traders with FCPA Bribery Scheme Involving Petrobras

In its first enforcement action of 2023, the Justice Department charged a Connecticut man and a foreign national with FCPA bribery and money laundering charges stemming from a bribery scheme to secure contracts with Petrobras in Brazil. Glenn Oztemel was a senior oil and gas trader at two trading companies., and Eduardo Innecco, a dual Italian and Brazilian citizen, was an oil and gas broker...

General

4 Jan, 2023

Digging into Honeywell UOP’s Bribery Schemes in Brazil and Algeria (Part II of III)

The facts surrounding Honeywell’s bribery schemes in Brazil and Algeria are fairly straightforward. In Brazil, the facts underscore the significant risks of bribery when companies participate in large, valuable project competitions. Global companies face significant risks when competing and seek every advantage to win a project competition. Brazil In 2008 and 2009, Petrobras developed the Premium Refinery project to design and construct two grassroots refineries...

General

8 Dec, 2020

Vitol’s Bribery Schemes in Brazil, Ecuador and Mexico (Part II of III)

Vitol’s bribery scheme stretched into three separate countries – Brazil, Ecuador and Mexico — and was carried out over a ten-year period. The Statement of Facts is instructive in describing the means by which Vitol used false documentation and financial arrangements involving offshore accounts, shell companies and correspondent banking transactions, Brazil: Confidential Information For a nine-year period, 2005 to 2014, Vitol paid more than $8...