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Jeffrey Chow Is The Lawyer Implicated Connection With The Keppel Offshore & Marine Enforcement Action

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In connection with last week’s net $105.5 million Foreign Corrupt Practices Act enforcement action against Keppel Offshore & Marine (see here for the prior post), the DOJ noted that it “also unsealed charges … against a former senior member of KOM’s legal department, who pleaded guilty to one count of conspiracy to violate the FCPA on Aug. 29, 2017 in the Eastern District of New York.”

That individual is Jeffrey Chow, a U.S. citizen and Tulane educated lawyer, who had various positions in the legal department of KOM “including Administrative Manager, General Manager and Director, from at least in or about and between 1990 and 2017.” (See here for the DOJ information).

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DOJ Announces FCPA Enforcement Action Against Former Embraer Exec Colin Steven

colin steven

In 2016, Embraer (a Brazil-based aircraft manufacturer with American Depositary Shares listed on the New York Stock Exchange) resolved a parallel DOJ / SEC Foreign Corrupt Practices Act enforcement action alleging improper conduct in the Dominican Republic, Saudi Arabia, Mozambique, and India (See here for the prior post).

The net FCPA settlement amount was $187 million and in terms of Saudi Arabia it was alleged that “Embraer [largely through the conduct of Executive B] agreed to pay and did pay Saudi Arabia Official [described as “an official in a high-level decision-making position in a state-owned and controlled company in Saudi Arabia that performed a government function] more than $1.5 million to obtain a contract for the sale of three business jets, valued at approximately $93 million to Saudi Arabia Instrumentality.”

Yesterday, the DOJ returned to these allegations and announced an enforcement action against Executive B, also known as Colin Steven (a U.K. citizen residing in the United Arab Emirates).

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FCPA Flash – A Conversation With Leslie Caldwell (Former Ass’t AG, DOJ Criminal Division) About The DOJ’s New “FCPA Corporate Enforcement Policy”

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The FCPA Flash podcast provides in an audio format the same fresh, candid, and informed commentary about the Foreign Corrupt Practices Act and related topics as readers have come to expect from written posts on FCPA Professor.

This FCPA Flash episode is a conversation with Leslie Caldwell. Caldwell is currently partner in the San Francisco and Silicon Valley offices of Latham & Watkins and previously served as the Assistant Attorney General of the DOJ’s Criminal Division. In this role, Caldwell was involved in implementing and promoting the DOJ’s April 2016 FCPA Pilot Program.

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Friday Roundup

Roundup

Former SEC FCPA Unit Chief Kara Brockmeyer on declinations and voluntary disclosure, Wal-Mart’s global chief ethics and compliance officer on increased standardization in global anti-corruption efforts, scrutiny updates, French first, and for the reading stack.

It’s all here in the Friday Roundup.

Former SEC FCPA Unit Chief Kara Brockmeyer On Declinations and Voluntary Disclosure

Brockmeyer is profiled in this recent Corporate Crime Report Q&A. (See here for a recent FCPA Flash podcast with Brockmeyer).

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DOJ Charges Two Individuals With FCPA And Other Violations In Connection With An African Bribery Scheme On Behalf Of CEFC China Energy Company Ltd.

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Yesterday, the DOJ announced that Chi Ping Patrick Ho (of Hong Kong, China) and Cheikh Gadio (of Senegal) were criminally charged with conspiring to violate the Foreign Corrupt Practices Act, violating the FCPA, conspiring to commit international money laundering, and committing international money laundering.

Although not specifically mentioned in the DOJ’s indictment, it is easy to connect the dots that Ho is associated with China Energy Fund Committee (CEFC) and as noted here, CEFC is “fully funded by CEFC China Energy Company Limited.” Gadio is associated with Sarata Holding (a consulting and advising firm specializing in business and development partnerships with Africa).

Big picture – in the past two weeks – the DOJ has announced three core FCPA enforcement actions involving 9 individuals. (See here for the November 7th action against 5 individuals associated with Rolls-Royce and here for the November 9th action against 2 individuals associated with SBM Offshore).

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