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This Week On FCPA Professor

May 30, 2020

FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.”

Set forth below are the topics discussed this week on FCPA Professor.

This post highlights various FCPA scrutiny alerts and updates.

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Friday Roundup

May 29, 2020

Fear based marketing, not a victim, dismissed, and for the reading stack.

It’s all here in the Friday roundup.

Fear Based Marketing

Another example of lawyers trying to market the COVID-19 situation by asserting that “the novel and exigent circumstances brought on by the pandemic significantly increase companies’ risk exposure under the Foreign Corrupt Practices Act and global anti-bribery laws.”

The piece even uses the personal protective equipment hypothetical that not even top DOJ officials seemed to be concerned about. (See here).

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Citgo Turns Plaintiff And Sues FCPA Violator For Bribing Its Employees

May 28, 2020

As highlighted in this prior post, in May 2019 Jose Manuel Gonzalez Testino pleaded guilty to, among other charges, one count of conspiracy to violate the Foreign Corrupt Practices Act and one count of violating the FCPA for providing things of value to Citgo Petroleum Corp. (a subsidiary of Petroleos de Venezuela S.A. – the Venezuelan state-owned oil company).

Recently, Citgo turned plaintiff and sued Testino and his associated company Petroleum Logistics Service Corp. (PLS) for bribing its employees.

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The Notion That The CROOK Act Is Going To Reduce “Pressure That U.S. Businesses Face To Pay Bribes Overseas” Is Fanciful

May 27, 2020

Previous posts here and here discussed House and Senate versions of the “Countering Russian and Other Overseas Kleptocracy Act” (“CROOK Act”).

Both versions of the CROOK Act seek to authorize the Secretary of State to establish a fund to be known as the “Anti-Corruption Action Fund” to aid foreign states to prevent and fight public corruption and develop rule of law based governance structures, including accountable investigative, prosecutorial, and judicial bodies, and supplement existing foreign assistance and diplomacy with respect to such efforts.”

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Scrutiny Alerts And Updates

May 26, 2020

This post highlights scrutiny alerts and updates regarding ABB Ltd. and former Florida congressman David Rivera.


As highlighted in this prior post, in early 2017  it was reported that ABB (a Swiss-based power and automation technology company) was cooperating with law enforcement authorities in the U.S. and the U.K. following a voluntary disclosure regarding its past dealings with Unaoil.

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