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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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Friday Roundup

Roundup

Convicted, sentenced, to FCPA Inc. and for the reading stack. It’s all here in the Friday Roundup.

Convicted

As noted in this DOJ release: “[Donville Inniss] a former member of the Barbados Parliament, who also served as the Minister of Industry of Barbados, was found guilty [of two counts of money laundering and one count of conspiracy to commit money laundering] by a federal jury for his role in a scheme to launder bribes paid to him by executives of the Insurance Corporation of Barbados Limited (ICBL).”

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In Connection With MTS Enforcement Action, DOJ Also Announces Individual FCPA Criminal Charges As Well As Money Laundering Charges Against Alleged “Foreign Official”

Karimova

In connection with the recent MTS Foreign Corrupt Practices Act enforcement action (see here for the prior post), the DOJ also announced FCPA and related criminal charges against Bekhzod Akhmedov (a citizen of Uzbekistan and former executive of an MTS entity) as well as money laundering charges against Gulnara Karimova (pictured – the former Uzbek official at the center of the telecom bribery scheme who allegedly had influence over the Uzbek governmental body that regulated the telecom industry).

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Money Laundering Charges Against Former Insurance Corp. of Barbados Executives Unsealed

innestasker

As highlighted in this prior post, in August 2018 the DOJ quietly released a so-called declination with disgorgement letter concerning Insurance Corporation of Barbados Ltd. (ICBL).

Pursuant to the agreement, ICBL agreed to pay approximately $94,000 for alleged bribes to a Barbadian government official in exchange for insurance contracts. As noted in the prior post, Donville Inniss (the “foreign official”) was charged with money laundering offenses.

In an August 2018 superseding indictment recently unsealed by the DOJ, Ingrid Innes (a Canadian citizen, resident of Barbados and former CEO of ICBL) and Alex Tasker (a citizen and resident of Barbados and former senior VP of ICBL) were also charged – not with FCPA anti-bribery violations – but with money laundering offenses. (For media coverage see here, for the DOJ’s release see here).

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SEC Finds That Former Panasonic Executive Authorized Conduct Causing Company’s FCPA Violations, Another Former Executive Found To Engage In Improper Revenue Recognition Practices

Margis

As highlighted in prior posts (here, here and here) in April 2018 the DOJ and SEC announced a $280 million Foreign Corrupt Practices Act enforcement action against Japan-based Panasonic Corp.  and a U.S. subsidiary Panasonic Avionics Corp. (PAC).

In the words of the government “between 2007 and 2013, PAC employees, including senior executives, engaged in a scheme to retain consultants for improper purposes other than for providing actual consulting services.”

Earlier this week, the SEC returned to the same core conduct to bring administrative actions (here and here) against Paul Margis (pictured – a former President and CEO of PAC) and Takeshi Uonaga (PAC’s former CFO). The Margis action finds that he authorized various conduct giving rise to the company’s FCPA liability, whereas the Uonaga matter is materially different in that it is a revenue recognition matter.

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