Scrutiny Alert
As highlighted in this prior post, there have been several FCPA (and related) enforcement actions involving Ecuador’s Seguros Sucre S.A., an alleged state-owned insurance company and “instrumentality” of the Ecuadorian government.
Recently, Arthur J. Gallagher & Co. (an Illinois based insurance brokerage, risk management and consulting services firm and a “World’s Most Ethical Company” for 11 consecutive years) disclosed:
The following are statements made by FCPA defendants immediately prior to being sentenced by a judge. (See here for a prior similar post).
Remorse. Regret. Shame.
Embarrassment, not only for themselves, but for their family and friends as well.
It’s all there the moment before a judge determines whether they lose their liberty and for how long.
The following are statements made by FCPA defendants immediately prior to being sentenced by a judge.
Remorse. Regret. Shame.
Embarrassment, not only for themselves, but for their family and friends as well.
It’s all there the moment before a judge determines whether they lose their liberty and for how long.
As highlighted in this prior post, in October 2019, the DOJ announced that Cyrus Ahsani and Saman Ahsani (the former CEO and Chief Operations Officer of Monaco-based Unaoil) pleaded guilty in March 2019 to one count of conspiracy to violate the FCPA for their roles in a scheme to corruptly facilitate millions of dollars in bribe payments to officials in multiple countries.
The DOJ also announced that Steven Hunter (a former business development manager at Unaoil) pleaded guilty in August 2018 to one count of conspiracy to violate the FCPA.
As noted in the DOJ’s release, the Ahsanis are scheduled to be sentenced in April 2020 and Hunter is scheduled to be sentenced in March 2020.
However, sentencing has yet to occur.
As highlighted here, in November 2021 announced the unsealing of a 2020 criminal complaint against agents associated with Odebrecht in connection with the company’s 2016 FCPA enforcement action (see here for the prior post).
Brothers Luis Enrique Martinelli Linares and Ricardo Alberto Martinelli Linares (both citizens of Panama and Italy and the sons of former Panamanian President Ricardo Martinelli) allegedly “participated in the Odebrecht bribery scheme by, among other things, serving as intermediaries for bribe payments and the provision of other things of value that Odebrecht offered and provided to the Panama Government Official (their father). The complaint alleged that, among other things, the defendants “established offshore bank accounts in the names of offshore shell companies to receive and disguise bribe payments from Odebrecht made for the benefit of the Panama Government Official.
The brothers pleaded guilty and were recently sentenced to 36 months in prison and were ordered to forfeit more than $18.8 million, pay a $250,000 fine, and serve two years’ supervised release. (See here for the DOJ release).
