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

By on December 27, 2017 in 2017 Enforcement Actions, DOJ Enforcement Action, Individual Enforcement Action, Jeffery Chow, Keppel Offshore & Marine
jchow

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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Keppel Offshore & Marine Resolves Net $105.5 Million FCPA Enforcement Action Based On Brazil Bribery Schemes

By on December 23, 2017 in 2017 Enforcement Actions, Brazil, Compliance, DOJ Enforcement Action, Foreign Non-Issuer Company, Keppel Offshore & Marine, Shipping Industry, Third Parties
Keppel

Do not finalize those 2017 Foreign Corrupt Practices Act statistics just yet. Similar to prior years, late December has become an active time for FCPA enforcement.

Yesterday, the DOJ announced a net $105.5 million enforcement action against Keppel Offshore & Marine Ltd. (a Singapore-based company which describes itself as a “global leader in offshore rig design, construction and repair, ship repair and conversion, and specialised shipbuilding”) and Keppel Offshore & Marine USA Inc. (a wholly-owned subsidiary based in Texas).

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DOJ Announces FCPA Enforcement Action Against Former Embraer Exec Colin Steven

By on December 22, 2017 in 2017 Enforcement Actions, Colin Steven, DOJ Enforcement Action, Embraer, Foreign Nationals, Individual Enforcement Action, Saudi Arabia, Saudi Aramco, Third Parties
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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SBM Offshore Resolves $238 Million FCPA Enforcement Action

By on November 29, 2017 in 2017 Enforcement Actions, Angola, Anything of Value, Brazil, DOJ Enforcement Action, Equitorial Guinea, Foreign Non-Issuer Company, Hiring Family Members of Foreign Officials, Iraq, Kazakhstan, Oil and Gas Industry, Paul Bond, SBM Offshore, Serious Fraud Office, Stephen Whiteley, Third Parties, Travel and Entertainment, Unaoil, United Kingdom, Voluntary Disclosure
sbm

As highlighted in this prior post, in 2014 Netherlands-based SBM Offshore resolved a $240 million Dutch law enforcement action alleging improper payments to sales agents and foreign government officials in Equatorial Guinea, Angola and Brazil between 2007 through 2011. In connection with this action, the company disclosed: ““the United States Department of Justice has informed SBM Offshore that it is not prosecuting the Company and has closed its inquiry into the matter.”

Fast forward to earlier this month when, as highlighted in this prior post, the DOJ announced resolution of criminal charges against former SBM Offshore executive Anthony Mace and Robert Zubiate for their roles in a scheme to bribe foreign government officials in Brazil, Angola and Equatorial Guinea.

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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.

By on November 21, 2017 in 2017 Enforcement Actions, Anything of Value, CEFC China Energy Company Limited, Chad, Charitable Contributions, Cheikh Gadio, Chi Ping Patrick Ho, DOJ Enforcement Action, Gifts, Individual Enforcement Action, Jurisdiction, Uganda, United Nations
ChinaEnergy

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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