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Just Following Instructions #precisionmatters

instructions

As DOJ compliance counsel, Hui Chen called out the “the lack of precision and intellectual rigor” in much compliance writing and commentary and was applauded on these pages for doing so.

Therefore, Chen encouraged others on social media to use #precisionmatters to “hold each other accountable and tag where more precisions are needed!”

Just following instructions here – #precisionmatters for Chen’s latest article for use of such terms as “centralized visibility,” “organizational culture,” “respect,” “engagement” etc.

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The Case That Keeps On Giving – DOJ Announces Additional Charges In PDVSA Bribery Action

PDVSA

Several prior posts (see here and here for instance) have highlighted the clustering phenomenon and how a few discreet instances of alleged bribery yield an inordinate amount of Foreign Corrupt Practices Act enforcement activity.

One such example is the DOJ’s long-standing enforcement action (charges were first brought in late 2015) in connection with alleged corrupt schemes to secure contracts from Venezuela’s state-owned and state-controlled energy company, PDVSA.

Yesterday, the DOJ announced that additional criminal charges were unsealed “against five former Venezuelan government officials for their alleged participation in an international money laundering scheme involving bribes made to corruptly secure energy contracts from Venezuela’s state-owned and state-controlled energy company, PDVSA.”

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Is This Appropriate?

846-05647896
© ClassicStock / Masterfile
Model Release: Yes
Property Release: No
1960s MAN THINKING HAND PENCIL ON CHIN WEARING EYEGLASSES SERIOUS EXPRESSION

Gibson Dunn is generally viewed as having a top tier Foreign Corrupt Practices Act practice.

The firm’s Year-End FCPA Update is always a quality read including this year’s version.

Yet, highlighted below is a paragraph from the Update that caught my eye and I ask: seriously – is this appropriate?

Early in the 36-page document is the following paragraph:

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Issues To Consider From The SBM Offshore Enforcement Action

Issues

This previous post went in-depth into the $238 million DOJ Foreign Corrupt Practices Act enforcement action against Netherlands-based SBM Offshore for alleged bribery schemes in Brazil, Angola, Equatorial Guinea, Kazakhstan and Iraq.

This post continues the analysis by highlighting additional issues to consider.

DOJ Explains Its Original “Declination”

As highlighted in the original post, in 2014 SBM Offshore resolved a $240 million Dutch law enforcement action alleging bribery schemes in Equatorial Guinea, Angola and Brazil between 2007 through 2011. In connection with that action, SBM Offshore disclosed: “the United States Department of Justice has informed SBM Offshore that it is not prosecuting the Company and has closed its inquiry into the matter.”

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SBM Offshore Resolves $238 Million FCPA Enforcement Action

sbm

As highlighted in this prior post, in 2014 Netherlands-based SBM Offshore resolved a $240 million Dutch law enforcement action alleging improper payments to sales agents and foreign government officials in Equatorial Guinea, Angola and Brazil between 2007 through 2011. In connection with this action, the company disclosed: ““the United States Department of Justice has informed SBM Offshore that it is not prosecuting the Company and has closed its inquiry into the matter.”

Fast forward to earlier this month when, as highlighted in this prior post, the DOJ announced resolution of criminal charges against former SBM Offshore executive Anthony Mace and Robert Zubiate for their roles in a scheme to bribe foreign government officials in Brazil, Angola and Equatorial Guinea.

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