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This Week On FCPA Professor

April 10, 2021

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 post highlights what you need to know from Q1.

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What Evidence Is There That Compliance Programs Actually Prevent Crime?

April 9, 2021

A guest post from Jon May (Jones Walker LLP)

Today we ask the question: “What evidence does the United States Department of Justice or the United States Sentencing Commission have that compliance programs actually prevent crime.”

The short answer is that there is none. Let’s talk about why.

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Former Gunvor Employee Pleads Guilty In Connection With Ecuador Bribery Scheme

April 8, 2021

Recently Raymond Kohut (a Canadian citizen who lived in the Bahamas and worked in business development for Gunvor Group Ltd., a Switzerland based commodities firm) pleaded guilty in connection with an Ecuador bribery scheme.

Similar to the DOJ’s recent money laundering charges against Jorge Cherrez Mino and John Robert Luzuriaga Aguinaga in connection with a bribery scheme in Ecuador (see here for the prior post), the DOJ’s allegations against Kohut provide a jurisdictional basis for FCPA anti-bribery offenses, yet the information “only” charges money laundering offenses.

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About Those Internship And Hiring Practices Enforcement Actions …

April 7, 2021

The most recent edition of the always informative FCPA Update from Debevoise & Plimpton has a lead article titled “Hiring a Foreign Official’s Family and Friends: The “Thing of Value” Under the FCPA.”

The article does a nice job summarizing the key points of the six internship and hiring practices enforcement actions since 2015 (BNY Mellon, Qualcomm, JP Morgan, Credit Suisse, Deutsche Bank and Barclays).

The article begins:

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FCPA Institute – Zoom (April 12-14)

April 5, 2021

Since 2014, the FCPA Institute has elevated the Foreign Corrupt Practices Act knowledge and practical skills of hundreds of professionals from around the world. In the current COVID environment, the traditional two-day in-person FCPA Institute is still not yet possible.

However, there remains a need for FCPA knowledge and skill development. After the inaugural FCPA Institute – Zoom was offered in November 2020 to a worldwide audience, I am pleased to offer another FCPA Institute – Zoom on April 12-14. The FCPA Institute – Zoom will consist of 9 hours of integrated and cohesive instruction (each day from 9 a.m. – noon central) led by Professor Koehler, an FCPA expert with FCPA practice and teaching experience.

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