Top Menu

Vantage Drilling Announces Closure Of DOJ Investigation, Just Don’t Call It A “Declination”

August 17, 2017

I hope the usual suspects don’t muddy up the conversation again by calling this one a “declination.” (See here for the recent post).

As highlighted in this August 2015 post, Houston-based Vantage Drilling disclosed:

“In July 2015, we became aware of media reports that our agent utilized in the contracting of the Titanium Explorer drillship has entered into a plea arrangement with the Brazilian authorities in connection with the agent’s role in obtaining bribes on behalf of former Petrobras executives.  We have since confirmed that our agent, who has represented multiple international companies in their contracts with Petrobras, has entered into such discussions and provided evidence to the Brazilian authorities of an alleged bribery scheme between the former Petrobras executives and a former director of Vantage.

Continue Reading

FCPA Flash – A Conversation With Neil Smith (Former Senior Counsel In The SEC’s Enforcement Division) About SEC FCPA Enforcement

August 16, 2017

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 Neil Smith. On July 14th, Smith left the SEC where he served as senior counsel in the Enforcement Division for more than six years and where he was also a member of the SEC’s FCPA Unit. In the podcast, Smith (currently a partner in the Boston office of K&L Gates) discusses SEC remedies in FCPA enforcement actions, the SEC’s theory of enforcement around the FCPA’s internal controls provisions, the impact of the Supreme Court’s recent Kokesh decision on SEC FCPA enforcement, and changes to the FCPA and FCPA enforcement that he would like to see.

Continue Reading

“Domestic Workers Who Have No Involvement In Foreign Sales Probably Don’t Need Training In The FCPA” – WRONG!

August 15, 2017

Navex Global claims to be the “ethics and compliance experts” and offers training courses that presumably seek to minimize a business organization’s FCPA risk.

However, in this recent post Navex asserts that “domestic workers who have no involvement in foreign sales probably don’t need training in the FCPA.”

This assertion is wrong on so many levels and if followed actually increases – not decreases – a business organization’s FCPA risk.

Continue Reading

Summer FCPA Reading List

August 14, 2017


A time for reflection, a time to think, a time to read.

If you have some downtime in these dog days of summer, put it to good use.

This post provides an overview of FCPA writings that can help you elevate your Foreign Corrupt Practices Act knowledge, sophistication, and practical skills.

Continue Reading

Elevate Your FCPA Knowledge At The FCPA Institute – Indianapolis (Sept. 28-29)

August 12, 2017

Could someone in your firm or organization benefit from a two-day, active learning experience devoted to the Foreign Corrupt Practices Act?

If so, please consider the FCPA Institute which is next making a stop in Indianapolis on September 28-29 and hosted by Quarles & Brady.

Since 2014, the FCPA Institute has elevated the FCPA knowledge and practical skills of over 100 diverse professionals through active learning and the below video introduces you to the FCPA Institute; how the FCPA Institute is different than other FCPA conferences; the substantive knowledge and practical skills participants will gain by attending the FCPA Institute; and what prior FCPA Institute “graduates” have said about their experience.

Continue Reading