Let’s recap. In my first post, I examined a limited set of circumstances where I believe it is reasonable under the FCPA to pay per diems to foreign officials.
In my second post, I looked at the enforcement agencies’ take on per diems by analyzing the FCPA Resource Guide as well as the Opinion Procedure Releases where the DOJ found it appropriate to make cash payments to foreign officials.… Continue Reading
The oil sector is well known for its corruption risks, but one corner of the industry has received less attention than it deserves: commodity trading.
Companies that engage in physical commodity trading, including such giants as Glencore, Trafigura, Gunvor and Vitol, often compete for high-value deals buying and selling oil and other commodities from governments, including those in countries where corruption is widespread.… Continue Reading
Procurement obviously presents among the highest risks for corruption. Brazil took its rare good fortune of hosting the 2014 FIFA World Cup and 2016 Summer Olympics as an opportunity to evaluate its procurement regime.… Continue Reading