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Friday Roundup

By on December 14, 2018 in CHS, Colin Steven, Enforcement Agency Policy, FCPA Sentences, Neither Admit or Deny
Roundup

No jail time for Stevens, scrutiny alert, neither admit nor deny airball, Jorgensen to depart Walmart, scrutiny alert and ripple. It’s all here in the Friday roundup.

No Jail Time for Steven

Further to the randomness of FCPA sentences (see here for the prior post), former Embraer executive Colin Steven (who plead guilty to causing $1.5 million in bribe payments to be made by Embraer to a Saudi Official in connection with a $93 million sale as well as receiving approximately $130,000 in kickbacks) was recently sentenced to no jail time. (See here for coverage).

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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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