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On Sale: Corsa Coal Resolves $1.2 Million Enforcement Action After The DOJ Concludes It Is Unable To Pay The Remaining $31.5 Disgorgement Amount


In 2021, the DOJ announced that Frederick Cushmore Jr. (an individual employed by Corsa Coal in various international sales positions) was criminally charged and plead guilty to a conspiracy charge to violate the FCPA’s anti-bribery provisions in connection with a bribery scheme in Egypt. (See here for the prior post).

In 2022, the DOJ announced that Charles Hunter Hobson (an individual employed by Corsa Coal in a variety of roles)  was also criminally charged in connection with the same core conduct. (See here for the prior post). The enforcement action against Hobson remains active with the next status conference scheduled for April 3rd.

Recently, the DOJ posted this “declination with disgorgement” letter to Corsa Coal’s counsel on its FCPA website.

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Bribes As “Breakfast” And “Breakfast Servings”


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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That Stinks: Safran S.A. Quietly Resolves $17.2 Million Enforcement Action Involving “Train Lavatory Contracts”


Some Foreign Corrupt Practices Act enforcement actions are accompanied by DOJ press releases and much fanfare and some are not.

In the later category, earlier this week this letter was quietly posted to the DOJ’s FCPA website indicating that Safran S.A. (a French company) resolved a $17.2 “declination with disgorgement” enforcement action.

According to the DOJ letter, bribery was “committed by employees and agents of the Company’s U.S. subsidiary Monogram Systems (Monogram) and its German subsidiary EVAC GmbH (EVAC).”

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


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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ABB Becomes The First Company To Resolve THREE FCPA Enforcement Actions


The first time ABB resolved a Foreign Corrupt Practices Act enforcement action was in 2004 concerning conduct in Nigeria, Angola and Kazakhstan.

The second time ABB resolved an FCPA enforcement action was in 2010 concerning conduct in Mexico as well as in connection with the Iraqi U.N. Oil for Food program.

Since 2017 (see here for the prior post), ABB has been under additional FCPA scrutiny and last Friday ABB became the first company to resolve an FCPA enforcement action for a third time. The latest enforcement action concerned conduct in South Africa and the net FCPA settlement amount was $147.5 million (a DOJ component of net $72.5 million and an SEC component of net $75 million).

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