Colombia Archives - FCPA Professor

Colombian Entities Resolve Net $60.6 Million FCPA Enforcement Action

By Mike Koehler on August 14, 2023 in 2023 Enforcement Action, Colombia, Corficolombiana, DOJ Enforcement Action, Financial Services Industry, Foreign Issuers, Grupo Aval, Odebrecht, SEC Enforcement Action

Once upon a time, a Colombian company (owned and controlled by another Colombian company with shares registered in the U.S.), through a wholly-owned and controlled subsidiary, agreed with a Brazilian company to form a joint venture and consortium to bid for public contracts with the Colombian government.

An executive of the Brazilian company informed an executive of the Colombian company that a Colombian lobbyist would help win projects by making bribe payments to Colombian officials and the Colombian company executive agreed.

That, in a nutshell, describes last week’s net $60.6 million Foreign Corrupt Practice Act enforcement action against Corporacion Financiera Colombiana S.A. (Corficolombiana) and Grupo Aval Acciones y Valores S.A. (Grupo Aval).

The enforcement action involved a DOJ component (in which the entities agreed to pay a net $20.3 million criminal penalty) and an SEC component (in which the entities agreed to pay approximately $40.3 million in disgorgement and prejudgment interest).

Latin America in Flux: Recent Anti-Corruption Developments

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

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.

FCPA Enforcement Actions Regarding Conduct In Colombia

By Mike Koehler on October 8, 2020 in Colombia

This prior post highlighted Foreign Corrupt Practices Act enforcement actions regarding conduct in Ecuador.

This post stays in the region by highlighting FCPA enforcement actions regarding conduct (in whole or in part) in Colombia.

Compared to South American countries Brazil, Venezuela, and Ecuador – Colombia has relatively modest oil reserves and thus the FCPA enforcement activity regarding conduct in Colombia represents a diverse range of companies.

Alexion Pharmaceuticals Resolves $21.5 Million Enforcement Action

By Mike Koehler on July 3, 2020 in 2020 Enforcement Action, Alexion Pharmaceuticals, Brazil, Colombia, Gaining Access to Confidential Documents, Permits / Licenses / Customs / Tax, Pharmaceutical Industry, Russia, SEC Enforcement Action, Third Parties, Turkey

Yesterday, the SEC announced that Alexion Pharmaceuticals (a company that has been under scrutiny since mid-2015) agreed to approximately $21.5 million to resolve an enforcement action based on the actions of foreign subsidiaries involving the company’s primary drug Soliris.

The conduct at issue focused on Alexion Illac Ticarent Limited Sirketi (Alexion Turkey), Alexion Pharma OOO (Alexion Russia), Alexion Pharma Brazil and Alexion Pharma Colombia SAS (all wholly-owned subsidiaries whose books and records were consolidated into Alexion’s financial statements).

A Look At The French Enforcement Action Against Airbus

By Mike Koehler on February 18, 2020 in Airbus, Charitable Contributions, China, Colombia, Doing Business With “Foreign Officials”, Due Diligence, France, Gaining Access to Confidential Documents, Nepal, Russia, Saudi Arabia, South Korea, Third Parties

Previous posts here and here looked at the U.S. Foreign Corrupt Practices Act enforcement action against Airbus.

This previous post looked at the U.K. Bribery Act enforcement action against Airbus.

This post completes the enforcement trilogy, bylooking at the French enforcement action against Airbus.

Like the prior U.S. and U.K. bribery enforcement action, the French enforcement action against Airbus (see here for the Judicial Public Interest Agreement) focused on the use of business partners in connection with sales or attempted sales in various countries.

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Colombian Entities Resolve Net $60.6 Million FCPA Enforcement Action

Latin America in Flux: Recent Anti-Corruption Developments

FCPA Enforcement Actions Regarding Conduct In Colombia

Alexion Pharmaceuticals Resolves $21.5 Million Enforcement Action

A Look At The French Enforcement Action Against Airbus

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