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Trace’s Bribery Risk Matrix Restates The Obvious

December 1, 2020

Recently Trace International released its Trace Bribery Risk Matrix.

Like other rankings of bribery and corruption, there is nothing per se wrong with the Bribery Risk Matrix. However, as stated several times on these pages (see here and here), I am not sure what these rankings really do (other than generate media coverage for the organization releasing the rankings) given that they generally restate the obvious (hence the picture of “Captain Obvious”).

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“Foreign Official” Status Disputed

November 30, 2020

In August 2020, the DOJ announced that Jose Luis De Jongh Atencio (De Jongh) “a former official at Citgo Petroleum Corporation, a Houston-based subsidiary of Venezuela’s state-owned and state-controlled energy company Petróleos de Venezuela S.A. (PDVSA)” was criminally charged “for his alleged role in laundering the proceeds of a scheme involving bribes made to corruptly secure business advantages from Citgo and PDVSA.”

In the indictment, the DOJ alleges that De Jongh was a “foreign official.”

Recently, De Jongh’s counsel (Dane Ball – Smyser Kaplan & Veselka LLP) filed a letter to the court stating in pertinent part (certain internal citations omitted):

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This Week On FCPA Professor

November 28, 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 FCPA Flash podcast episode is a conversation with the lawyer who successfully represented “victims” of Och-Ziff’s bribery scheme – resulting in a $138 million restitution award for his clients.

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Acting Assistant AG Rabbitt Talks White-Collar Crime

November 27, 2020

Recently Acting Assistant Attorney General Brian Rabbitt delivered this virtual speech to a White Collar Crime workshop.

As excerpted below, Rabbitt touched upon a variety of white-collar crime topics including individual accountability, DOJ policy, and data analytics.

Regarding white-collar crime generally, Rabbitt stated:

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November 26, 2020

I hope this Thanksgiving finds you being thankful for many things in your life.

Among the many things I am thankful for are your readership and I hope FCPA Professor elevates your FCPA knowledge and skills.

May your turkey be golden brown.

The following FCPA enforcement actions have involved, in whole or in part, alleged improper conduct in Turkey.

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