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Bribes As “Breakfast” And “Breakfast Servings”

By on February 24, 2023 in 2023 Enforcement Action, Brazil, DOJ Enforcement Action, Freepoint Commodities, Individual Enforcement Action, Oil and Gas Industry
breakfast

Earlier this week the DOJ announced that “Glenn Oztemel (who worked as a senior oil and gas trader at two Connecticut-based trading companies (Trading Company #1 and Trading Company #2) and Eduardo Innecco (a dual Brazilian and Italian citizen who worked as an oil and gas broker and agent for Trading Company #1 and Trading Company #2 in Brazil) were charged with FCPA and related offenses for an alleged Brazil bribery scheme.

As highlighted here, Oztemel was previously employed by Freepoint Commodities LLC.

In summary fashion, the indictment alleges:

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Honeywell Resolves Net $82 Million FCPA Enforcement Action Concerning Conduct In Brazil And Algeria

By on December 20, 2022 in 2022 Enforcement Action, Algeria, Brazil, DOJ Enforcement Action, Honeywell, Oil and Gas Industry, SEC Enforcement Action, Third Parties, Unaoil
Honeywell

Turns out, things were not so well at Honeywell.

As highlighted in this prior post, in mid-2019 Honeywell disclosed that it was cooperating with the DOJ/SEC and Brazilian law enforcement investigations relating to its use of third parties in relation to Petrobras (Brazil) business as well as a matter involving a foreign subsidiary’s prior engagement of Unaoil in Algeria.

Yesterday, the DOJ and SEC announced (see here and here) a parallel Foreign Corrupt Practices Act enforcement action against Honeywell UOP (a U.S. based subsidiary of Honeywell International) and Honeywell International.

The net $82 million enforcement action involved a DOJ component (net $39.6 million) and an SEC component (net $42.4 million).

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Brazilian Airline Bribes Brazilian Officials – U.S. Collects Net $38.1 Million In FCPA Enforcement Action

By on September 16, 2022 in 2022 Enforcement Action, Airline Industry, Brazil, DOJ Enforcement Action, Foreign Issuers, SEC Enforcement Action
GOL

Yesterday, the DOJ and SEC (see here and here) announced a parallel Foreign Corrupt Practices Act enforcement action against Gol Linhas Aereas Inteligentes S.a. (GOL) – an airline headquartered in Sao Paulo, Brazil with shares traded on the New York Stock Exchange.

The DOJ component involved a criminal information against GOL charging conspiracy to violate the FCPA’s anti-bribery and books and records provisions resolved through a deferred prosecution agreement in which the company agreed to pay net $15.3 million. The SEC component involved an administrative order against GOL finding violations of the FCPA’s anti-bribery, books and records, and internal controls provisions pursuant to which the company is expected to pay net $22.8 million.

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Latin America in Flux: Recent Anti-Corruption Developments

By on August 29, 2022 in Argentina, Brazil, Chile, Colombia, El Salvador, Guatemala, Guest Posts, Honduras, Mexico, Peru, Uncategorized
latinamerica

Today’s post is from Debevoise attorneys Andrew Levine, Matthew French, and Nestor Almeida. (See here for a version of this post with footnotes).

In recent years – and notwithstanding encouraging windows of progress – economic difficulties, political shifts, and the pandemic’s lingering effects have undercut anti-corruption efforts in Latin America. The fourth annual Capacity to Combat Corruption Index (“CCC Index”), published in June 2022, reflects these recent challenges. Most countries in Latin America experienced declines in their assessed anti-corruption capabilities, with only a few demonstrating stability or improvement.

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The FCPA Repeat Offender Club Welcomes Tenaris

By on June 3, 2022 in 2022 Enforcement Action, Brazil, Foreign Issuers, Oil and Gas Industry, SEC Enforcement Action, Tenaris
welcome

In 2011, Tenaris S.A. (a company headquartered in Luxembourg with American Depository Receipts listed on the New York Stock Exchange) resolved an approximate $9 million Foreign Corrupt Practices Act enforcement action regarding conduct in Uzbekistan (see here for the prior post).

For several years, Tenaris has been under scrutiny for its relationship with Petrobras in Brazil and in October 2016 the company “voluntarily notified” the SEC and DOJ. (See here).

Yesterday, the FCPA Repeat Offender Club welcomed Tenaris to its growing membership as the SEC announced an approximate $78.1 million enforcement action against the company.

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