In a December 2018 enforcement settlement, the SEC and Brazil’s Centrais Elétricas Brasileiras S.A. (“Eletrobras”) agreed to violating books and records and internal accounting controls requirements and paid a $2.5 million penalty. (Here). DOJ declined to prosecute Eletrobras. Eletrobas stock is traded on the New York Stock Exchange. The Brazilian government owns 51 percent of Eletrobras and appoints seven of eleven board members. The bribery...
Listen to the Corruption, Crime & Compliance Podcast
Subscribe to Corruption, Crime & Compliance
- Root Cause Analysis: A Critical Ethics and Compliance Practice February 25, 2021
- FCPA Themes from 2020 with Compliance Commentary February 19, 2021
- Common Pitfalls – Fraud Risk Assessment February 12, 2021
- The Continued Evolution of Best Practices for Compliance Programs! February 10, 2021
- Red Flags That May Indicate You Might be at Risk of Violating FCPA February 3, 2021