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Stiffed By Co-Conspirators, Individual Cooperates With Government And The End Result Is Yet Another FCPA Enforcement Action Concerning Conduct In Venezuela

By on June 28, 2019 in 2019 Enforcement Actions, Egbert Yvan Ferdinand Koolman, Electronics Industry, Eustiquio Jose Lugo Gomez, Individual Enforcement Action, Jesus Ramon Veroes, Luis Alberto Chacin Haddad, Luis Alfredo Motta Dominguez, Origins of FCPA Actions, Venezuela
corpoelec

Earlier this week, the DOJ announced yet another Foreign Corrupt Practices Act and related enforcement action concerning conduct in Venezuela.

Jesus Ramon Veroes and Luis Alberto Chacin Haddad were each charged and plead guilty to conspiracy to violate the FCPA’s anti-bribery provisions in connection with obtaining various contracts with Corporacion Electric Nacional S.A. (Corpoelec), Venezuela’s state-owned electric company.

In the resolution documents, Veroes is described as a Venezuelan citizen whose close relative is the President of NV Oriental Trading Corporation (a company based in Doral, Florida) and Chacin is described as a Venezuelan citizen and resident of the U.S. who owns and manages businesses in Miami including Search Trading LLC and Headline LLC (companies that purchase goods from around the world for export to Central and South America).

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Friday Roundup

By on June 29, 2018 in Egbert Yvan Ferdinand Koolman, FCPA Sentences, Lawrence Parker, Leighton Holdings, McKinsey & Co., SBM Offshore, Serious Fraud Office, Unaoil, United Kingdom
Roundup

Across the pond, sentenced, unremarkable, and nonsense. It’s all here in the Friday roundup.

Across the Pond

As highlighted in this prior post, in July 2016 the U.K. Serious Fraud Office announced:

“The SFO is conducting a criminal investigation into the activities of Unaoil, its officers, its employees and its agents in connection with suspected offences of bribery, corruption and money laundering.”

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The Panama Papers Origins Of The Parker FCPA Enforcement Action

By on April 16, 2018 in Egbert Yvan Ferdinand Koolman, Lawrence Parker, Origins of FCPA Actions, Panama Papers, Related Civil Litigation
PanamaPapers

This recent post highlighted the DOJ’s Foreign Corrupt Practices Act enforcement action against Lawrence Parker in connection with a telecommunications bribery scheme in Aruba in which the DOJ alleged that Servicio di Telecommunicacion di Aruba N.V. (SETAR) was an instrumentality of the Aruban government such that Egbert Yvan Ferdinand Koolman (a product manager at SETAR and alleged bribe recepient) was a “foreign official.”

This post highlights that the likely origin of the FCPA enforcement action against Parker was this March 2017 civil complaint filed in U.S. court by SETAR against Koolman, Parker and several other entities and individuals and how the civil complaint originated with the so-called Panama Papers.

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DOJ Announces Individual FCPA And Related Enforcement Action In Connection With Aruba Telecom Scheme

By on April 13, 2018 in 2018 Enforcement Actions, Aruba, DOJ Enforcement Action, Egbert Yvan Ferdinand Koolman, FCPA Related Charges, Individual Enforcement Action, Lawrence Parker, Telecommunications Industry
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It’s not every day that the DOJ announces a Foreign Corrupt Practices Act enforcement casually in a press release about another enforcement action, but that is what the DOJ did today in this release announcing that Egbert Yvan Ferdinand Koolman (a Dutch citizen residing in Miami, Florida who was an official of Servicio di Telecommunicacion di Aruba N.V. (Setar), an instrumentality of the Aruban government) pleaded guilty to one count of conspiracy to commit money laundering involving FCPA violations.

The release further states: “in connection with the scheme, Lawrence W. Parker, Jr., 42, of Miami, pleaded guilty on Dec. 28, 2017 to one count of conspiracy to violate the Foreign Corrupt Practices Act (FCPA) and to commit wire fraud.  Parker’s sentencing is scheduled for April 30.”

This post summarizes the original source documents in the Parker enforcement action.

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