Around 90 percent of all FCPA enforcement actions involve third-party intermediaries. So it’s no wonder the DOJ’s updated guidance for evaluating corporate compliance programs devotes an entire section to “Third-Party Management.”… Continue Reading
An executive who controlled several U.S.-based companies pleaded guilty Wednesday to bribing officials at subsidiaries of Venezuela’s state energy company.
Jose Manuel Gonzalez Testino (Gonzalez), 49, of Miami, Florida, pleaded guilty in federal court in Houston to one count of conspiracy to violate the Foreign Corrupt Practices Act, one count of violating the FCPA, and one count of failing to report foreign bank accounts. … Continue Reading
The World Bank Wednesday debarred two subsidiaries of Paris-based Veolia Water Technologies for “fraudulent and collusive practices” involving a project in Colombia.
France’s OTV was debarred for two years and Veolia Water Technologies Brasil Ltda was debarred for one year.… Continue Reading
Once again, AML failures are shaking up the headlines. If the Danske Bank scandal wasn’t enough, at the beginning of March, the Organized Crime and Corruption Reporting Project showed how a series of offshore shell companies were used to move billions of dollars of private wealth from Russia to the West.… Continue Reading
SCOTUS News: Limits on immunity for Multilateral Development Banks should spur increased anti-corruption efforts
Earlier this year, the U.S. Supreme Court held that the protections in the International Organizations Immunities Act of 1945 (IOIA) against civil lawsuits in U.S. courts were not absolute. Instead, the immunity provided to international organizations — including Multilateral Development Banks (MDBs) — was no greater than the immunity enjoyed by foreign governments under the Foreign Sovereign Immunities Act.… Continue Reading
Preet Bharara gave the morning keynote at the second day of Compliance Week 2019. It was interesting because rather than a speech he did so with a one-hour Q&A format with Allen & Overy partner Gene Ingoglia facilitating the session through the role of the questioner.… Continue Reading
The Mexican Social Security Institute (IMSS) has defied conventional wisdom to become a leader in reforming the country’s anti-corruption efforts. The giant agency historically lacked an effective compliance program, with many responsibilities left to the functioning of internal controls — an audit-related system with no power to remedy operational compliance gaps.… Continue Reading
The World Bank debarred a Chinese fiber optic cable manufacturer and distributor Wednesday for 20 months for “fraudulent practices” involving a project in Zambia.
Nantong-based Jiangsu Zhongtian Technology Co., Ltd. (ZTT) is ineligible to participate in World Bank-financed projects during the 20-month debarment.… Continue Reading
Last year just before the “big date” of May 25, I wrote a post trying to analyze GDPR provisions through the lens of the whistleblowing process. At that time there were many questions ranging from how the rules will apply to whistleblowing on a national level to how to balance individuals’ privacy rights against companies’ need to pursue investigations.… Continue Reading
It is no secret that the global commodities trading sector is rife with corruption risks. We at Global Witness have been investigating this for years, and have seen enforcement efforts fall short all too often.… Continue Reading