Tagged: Third Party Intermediary

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...

Bribery Requires – Money

I have to confess – I love the show Shark Tank. Mr. Wonderful, Kevin O’Leary, is my favorite Shark. Mr. Wonderful often reminds the contestants and other Sharks that the central issue in considering business proposals is – How do I make M-O-N-E-Y? The same focus on money has to be at the core of any anti-corruption compliance program. In examining a company’s risk profile,...