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DOJ Announces Individual FCPA And Related Enforcement Action In Connection With Aruba Telecom Scheme

setar

It’s not every day that the DOJ announces a Foreign Corrupt Practices Act enforcement casually in a press release about another enforcement action, but that is what the DOJ did today in this release announcing that Egbert Yvan Ferdinand Koolman (a Dutch citizen residing in Miami, Florida who was an official of Servicio di Telecommunicacion di Aruba N.V. (Setar), an instrumentality of the Aruban government) pleaded guilty to one count of conspiracy to commit money laundering involving FCPA violations.

The release further states: “in connection with the scheme, Lawrence W. Parker, Jr., 42, of Miami, pleaded guilty on Dec. 28, 2017 to one count of conspiracy to violate the Foreign Corrupt Practices Act (FCPA) and to commit wire fraud.  Parker’s sentencing is scheduled for April 30.”

This post summarizes the original source documents in the Parker enforcement action.

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Friday Roundup

Roundup

Elevate, further to the clustering phenomenon, transparency, dismissed, and incomplete. It’s all here in the Friday roundup.

Elevate

Learning a new topic or elevating your knowledge and practical skills in a topic is not just for formal students in formal educational settings. Professionals in the workplace can also benefit from back to “school” experiences.

For professionals in the FCPA space – or wishing to join the FCPA space – the FCPA Institute serves this objective and has “graduated” approximately 200 hundred diverse professionals since its launch in 2014.

The next FCPA Institute will take place in Nashville on May 3-4th. See here to learn more and to register.

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DOJ Once Again Returns To Russia Nuclear Bribery Scheme As Transport Logistics International Resolves $2 Million Enforcement Action

TENEX

As highlighted in this prior post, in August 2015 the DOJ announced a Foreign Corrupt Practices Act and related enforcement action against Daren Condrey (an owner and executive of Maryland-based Transport Logistics International – TLI) and Vadim Mikerin (an alleged Russian “foreign official”) in connection with a nuclear industry bribery scheme.

As highlighted in this prior post, Mikerin (a Maryland resident) worked for a Maryland corporation (TENAM Corporation), but the DOJ considered him a Russian “foreign official” because TENAM was a wholly-owned subsidiary on TENEX – an entity “indirectly owned and controlled by, and performed functions of, the government of the Russian Federation.”

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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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DOJ FCPA Enforcement – 2017 Year In Review

DOJ

This previous post highlighted various corporate enforcement statistics from 2017 and this post goes in-depth into various facts and figures relevant to DOJ FCPA enforcement in 2017. (See here for a similar post from 2016, here for a similar post from 2015, here for a similar post from 2014, here for a similar post from 2013, here for a similar post from 2012, here for a similar post from 2011, and here from 2010).

Settlement Amounts and Specifics

In 2017, the DOJ brought 9 corporate FCPA enforcement actions.

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