Tagged: shell company

Lessons Learned from the Telefónica FCPA Settlement (Part III of III)

Lessons Learned from the Telefónica FCPA Settlement (Part III of III)

The Justice Department’s record of FCPA enforcement in 2024 has been disappointing.  With all of the hoopla and pronouncements surrounding the global war against corruption, DOJ suggested that enforcement in 2023 and 2024 would be robust.  Instead, 2024 was a year of fizzles, fits and starts, and ultimately a slow year of FCPA enforcement. The future under the Trump Administration will be interesting.  Based on...

Embraer Finally Lands $205 Million FCPA Settlement (Part I of II)

After years of investigation, disclosures, and press reports, the Embraer FCPA case finally came to a close. Hopefully, we will not see more of these long-term, seemingly endless investigations. The Justice Department and the SEC have publicly committed to moving FCPA investigations more expeditiously. In any event, Embraer settled its case for $205 million with the Justice Department and the SEC. The case itself has...