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Former Gunvor Employee Pleads Guilty In Connection With Ecuador Bribery Scheme

gunvor

Recently Raymond Kohut (a Canadian citizen who lived in the Bahamas and worked in business development for Gunvor Group Ltd., a Switzerland based commodities firm) pleaded guilty in connection with an Ecuador bribery scheme.

Similar to the DOJ’s recent money laundering charges against Jorge Cherrez Mino and John Robert Luzuriaga Aguinaga in connection with a bribery scheme in Ecuador (see here for the prior post), the DOJ’s allegations against Kohut provide a jurisdictional basis for FCPA anti-bribery offenses, yet the information “only” charges money laundering offenses.

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DOJ Announces Individual Criminal Charges In Connection With Ecuador Bribery Scheme

JorgeCherrezMino

Yesterday, the DOJ announced criminal charges against Jorge Cherrez Mino (pictured) and John Robert Luzuriaga Aguinaga in connection with a bribery scheme in Ecuador.

According to this criminal complaint, Cherrez (a citizen of Ecuador who is currently located in Mexico) served as the manager, president, and director of the “U.S. Investment Fund Companies” (a domestic concern under the FCPA).

According to this separate criminal complaint, Luzuriaga (a citizen of Ecuador who is currently located in Florida) served as the Risk Director for Instituto de Seguridad Social de la Policia Nacional (“ISSPOL” – an Ecuadorian public institution responsible for managing the financial contributions by Ecuadorian police officers toward their social security). The complaint alleges that “ISSPOL was controlled by the government of Ecuador and performed a function that Ecuador treated as its own, and was an ‘instrumentality’ of the Ecuadorian government.”)

Even though the Cherrez complaint provides a jurisdictional basis for FCPA anti-bribery offenses and indeed alleges that Cherrez violated the FCPA, the Cherrez and Luzuriaga complaints charge money laundering offenses.

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Vitol Resolves Net $90 Million FCPA Enforcement Action For Conduct In Brazil, Ecuador And Mexico

vitol

Last week the DOJ announced that Vitol Inc., the U.S. affiliate of the Vitol group of companies, which together form one of the largest energy trading companies in the world, agreed to resolve a net $90 million FCPA enforcement action for conduct in Brazil, Ecuador and Mexico.

As noted in the DOJ release (and as will be explored in a future post) “Vitol has also agreed to disgorge more than $12.7 million to the Commodity Futures Trading Commission (CFTC) in a related matter and to pay the CFTC a penalty of $16 million related to trading activity not covered” by the DOJ enforcement action.

Under the heading “The Brazil Bribery Scheme” this criminal information alleges:

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FCPA Enforcement Actions Regarding Conduct In Ecuador

Ecuador

Ecuador.

It is on the smaller side of countries in South America in terms of population and land area. However, it has the third largest oil reserves in South America and thus many companies subject to the Foreign Corrupt Practices Act do business in the country.

This post summarizes FCPA enforcement actions regarding conduct (in whole or in part) in Ecuador.

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Sargeant Marine Cements $16.6 FCPA Resolution With DOJ Regarding Bribery Schemes In Brazil, Venezuela, And Ecuador

Sargeant Marine

Earlier this week, the DOJ announced that Sargeant Marine Inc. (SMI – an asphalt company based in Florida) “pleaded guilty and agreed to pay $16.6 million to resolve foreign bribery charges stemming from conduct by the company and its employees and agents in Brazil, Venezuela and Ecuador.”

The total criminal penalty was actually $90 million, but because of SMI’s “inability to pay” the settlement amount was only $16.6 million.

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