A federal appeals court Friday affirmed the DOJ’s expansive view of a “foreign official” under the FCPA, upholding Joel Esquenazi and Carlos Rodriguez’s convictions, and keeping intact the longest prison sentence ever imposed in an FCPA case.… Continue Reading
Posts Tagged: Foreign Official
The opinion request came from “a United States financial services company and investment bank,” the DOJ said.… Continue Reading
Among the more than $10,000 in gifts Dennis Rodman delivered to North Korea dictator Kim Jong Un in Pyongyang this month were “hundreds of dollars’ worth of Irish Jameson whiskey, European crystal, an Italian suit, a fur coat, and an English Mulberry handbag for Kim’s wife, Ri Sol-ju,” the Daily Beast said Friday.… Continue Reading
On December 19, the Justice Department published FCPA Opinion Procedure Release No. 13-01, ruling that a law firm partner could pay some medical expenses of foreign official’s daughter.
The lawyer’s firm billed the foreign country over $2 million for the past 18 months, and expects to bill the same amount in 2014.… Continue Reading
A U.S. Foreign Service Officer who was posted in Vietnam admitted accepting more than $3 million in bribes to process visas for entry into the United States, the DOJ said.
Michael T.… Continue Reading
DOJ has opened a criminal bribery investigation into the nonprofit, National Geographic Society, and the details are worthy of another Indiana Jones movie or an Egypt-based episode of the Bones TV show.… Continue Reading
Ohio-based Diebold Inc. agreed Tuesday to pay a criminal fine of $25.2 million to the DOJ and $23 million in disgorgement and prejudgment interest to the SEC to resolve allegations it violated the Foreign Corrupt Practices Act by covering up bribes to bank officials in China, Indonesia and Russia.… Continue Reading
The U.S. Court of Appeals for the 11th Circuit will hear oral arguments Friday from two defendants convicted in the Haiti telco case. They’re challenging the DOJ’s interpretation of ‘foreign official’ under the Foreign Corrupt Practices Act.… Continue Reading
JP Morgan Chase is willing to pay up to $3 billion to settle a number of current U.S. investigations, including the FCPA probe of its hiring practices, according to a report Tuesday from the Wall Street Journal.… Continue Reading
In the previous four posts, we examined how the practice of allowing public officials to appear in films could be used as an alternative method of bribery. While we’ve focused on the idea of a foreign official receiving a cameo, the analysis actually applies to anyone who has a substantial enough connection to a foreign official.… Continue Reading
This is the fourth of five posts looking at Hollywood’s practice of giving film cameos to politicians and how this practice would play in an FCPA context.
Even if a filmmaker gives value to a foreign official by offering the official a film role in exchange for an unfair business advantage, the FCPA will not apply without corrupt intent.… Continue Reading
As we’ve seen in Part I and Part II of this series, a political cameo is valuable enough to operate as a bribe, but does Hollywood really need to worry about the practice exposing it to FCPA liability?… Continue Reading