Tagged: SEC FCPA

DOJ FCPA Settlement: J&F Investimentos’ Bribery Schemes (Part II of V)

J&F’s Investimentos bribery scheme was pervasive and was coordinated with a senior Brazilian Finance minister and orchestrated through the use of United States banking.  The Brazilian official appears to be Guido Mantega, who went on to serve as Brazil’s finance minister. Given J&F’s large penalty in Brazil, DOJ’s resolution was reasonable in light of the consistent use of the US banking system to execute the...

J&F Investimentos Pleads Guilty to FCPA Bribery Conspiracy and Settles SEC Case for Total of $283 Million (Part I of V)

J&F Investmentos SA (“J&F), a Brazilian private investment company, plead guilty to FCPA bribery violations in federal court in Brooklyn, New York.  As part of the plea agreement, J&F agreed to pay a fine of $256 million and to cooperate with ongoing investigations of other companies and individuals involved in the bribery schemes. J& F owns numerous companies around the globe, including in the meat...

Webinar: 2020 FCPA Enforcement and Compliance Review

Webinar: 2020 FCPA Enforcement and Compliance Review October 13, 2020, 12 Noon EST Sign Up HERE Despite the pandemic and disruptions to the global economy, the Justice Department and the Securities and Exchange Commission have resumed their aggressive enforcement of the FCPA. DOJ has continued its pace of corporate prosecutions while continuing to increase individual criminal prosecutions. DOJ and the SEC also issued a revised...

World Acceptance Corporation Settles FCPA Charges with the SEC for $21.7 Million

World Acceptance Corporation (“WAC”), a US-based consumer loan company, agreed to pay the SEC $21.7 million for FCPA violations in Mexico.  WAC’s cited violations covered the full gamut of FCPA violations, including bribery payments to government officials in Mexico, failure to keep accurate books and records and inadequate internal accounting controls. WAC engaged in an illegal scheme over a seven year period, from December 2010...

Episode 149 — A Deep Dive into the Alexion’s SEC Settlement for $21 Million for FCPA Violations

Notwithstanding the pandemic and remote working arrangements, the Securities and Exchange Commission is continuing to bring FCPA enforcement actions.  In its latest action, the SEC settled with Alexion Pharmaceuticals for $21 million for foreign bribery and books and records violations.  In this Episode, Michael Volkov reviews the Alexion FCPA enforcement action and the lessons learned for compliance professionals.

ENI Pays SEC $24.5 for FCPA Violations

Despite the COVID-19 pandemic crisis, the SEC is continuing its FCPA enforcement activities.  The SEC lawyers and staff have brought two cases recently – an enforcement action against a former Goldman Sachs executive and the settlement with ENI which was announced on Friday. HERE. During the relevant period, between 2007 and 2010, ENI held a 43 percent minority-control interest in Saipem S.p.A. ENI’s American Depositary...

SEC Charges Ex-Goldman Investment Banker for FCPA Bribes in Ghana Power Project

Last week, the Securities and Exchange Commission (“SEC”) filed charges against Asante Berko, a former Goldman Sachs executive with bribery of foreign government officials in Ghana.  Goldman Sachs discovered and stopped the scheme and then reported it to the government.  Goldman Sachs was not charged with the conduct and cooperated with the investigation. The SEC’s complaint charged Berko with assisting a client, a Turkish energy...

Cooperating Cognizant COO Pays $50K to Settle SEC FCPA Action

In an interesting SEC FCPA settlement action, Sridhar Thiruvengadam, the former COO of Cognizant Technology, agreed to pay a $50K penalty for his role in the bribery scheme involving the payment of $2 million to a government official in India in exchange for the issuance of a planning permit needed for the construction of Cognizant’s new office location in Chennai, India.  Early this year, Cognizant...

Juniper Networks Settles FCPA Violations with SEC for $11.7 Million

Juniper Networks agreed to pay the SEC $11.7 million to settle FCPA violations for conduct occurring in Russia and China.  See Order Here.  Under the settlement, Juniper Networks agreed to disgorgement of $4 million, a $6.5 million civil penalty, and pre-judgment interest of $1.3 million. The Juniper Networks investigation was initiated approximately six years ago in 2013.  The Justice Department had declined to prosecute Juniper...