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Scrutiny Alert 

As highlighted in this prior post, there have been several FCPA (and related) enforcement actions involving Ecuador’s Seguros Sucre S.A., an alleged state-owned insurance company and “instrumentality” of the Ecuadorian government.

Recently, Arthur J. Gallagher & Co. (an Illinois based insurance brokerage, risk management and consulting services firm and a “World’s Most Ethical Company” for 11 consecutive yearsdisclosed:

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Friday Roundup


Under scrutiny again, guilty plea, and for your listening enjoyment.

It’s all here in the Friday roundup.

Under Scrutiny Again

As highlighted in this prior post, in 2019 Russia-based Mobile TeleSystems PJSC (MTS) agreed to resolve an $850 million DOJ/SEC FCPA enforcement action based on the same alleged core conduct in several other Uzbekistan telecom focused FCPA enforcement actions. (See here and here). As a condition of settlement, MTS was required to retain an independent compliance monitor.

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DOJ Returns To Ugandan Bribery Scheme To Bring Additional Individual Charges


As highlighted in this prior post, in August 2019 the DOJ announced that Robin Longoria (an individual associated with European Adoption Consultants – an Ohio-based adoption agency) pleaded guilty to one count of conspiring to violate the FCPA’s anti-bribery provisions and to commit wire fraud and visa fraud “for her role in a scheme to corruptly facilitate adoptions of Ugandan children through bribing Ugandan officials and defrauding U.S. adoptive parents and the U.S. Department of State.”

Yesterday, the DOJ announced additional individual FCPA criminal charges, among others, in connection with the same Ugandan bribery scheme.

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