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Chemical Company Albemarle Resolves A Net $218.4 Million Enforcement Action


As highlighted in this prior post, in February 2018 Albemarle Corp. (a North Carolina based chemical company) disclosed Foreign Corrupt Practices Act scrutiny.

More than 5.5 years later, the DOJ and SEC announced a net $218.4 million FCPA enforcement action against the company.

The resolution included a DOJ non-prosecution agreement (pursuant to which the company agreed to pay a $98.2 million criminal penalty and $16.6 million in forfeiture) and an SEC administrative order (pursuant to which the company agreed to pay approximately $103.6 million in disgorgement and prejudgment interest).

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Venezuelan Citizen Charged With FCPA Offenses In Connection Venezuelan Food Bribery Scheme


Earlier this week a criminal information was filed in the Southern District of Florida charging Orlando Alfonso Contreras Saab (a citizen of Venezuela) with conspiracy to violate the FCPA in connection with an alleged Venezuelan bribery scheme.

According to the information, Contreras Saab and his co-conspirators “unlawfully enrich[ed] themselves by engaging in a scheme to bribe Venezuelan officials to obtain and retain contracts and other business advantages, including obtaining mutli-million-dollar contracts with entities and instrumentalities owned and controlled by the Venezuelan government for the production, importation, and distribution of food and medicine to the people of Venezuela.”

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Brother Added To FCPA Enforcement Action Alleging Brazil Bribery Scheme


As highlighted in this prior post, in February 2023 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.

In summary fashion, the indictment alleged:

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Colombian Entities Resolve Net $60.6 Million FCPA 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).

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Bankman-Fried Charged With FCPA Offense


In December 2022, the Department of Justice announced criminal charges against Samuel Bankman-Fried arising from an “alleged wide-ranging scheme by [him] to misappropriate billions of dollars of customer funds deposited with FTX, the international cryptocurrency exchange [he] founded …, and mislead investors and lenders to FTX and to Alameda Research, the cryptocurrency hedge fund [he] also founded.”

Specifically, Bankman-Friend was charged with conspiracy to commit wire fraud, wire fraud, conspiracy to commit commodities fraud, conspiracy to commit securities fraud, conspiracy to commit money laundering, and conspiracy to defraud the Federal Election Commission and commit campaign finance violations.

Yesterday, the DOJ filed a superseding indictment adding a Foreign Corrupt Practices Act conspiracy charge to the criminal charges Bankman-Fried is facing.

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