Foreign Law Enforcement Cooperation Archives

Friday Roundup

By Mike Koehler on December 13, 2019 in Compliance, Ericsson, Foreign Law Enforcement Cooperation

Head scratcher, expense reports, and third-party compliance. It’s all here in the Friday roundup.

Head Scratcher

In the bribery and corruption space, the DOJ and SEC frequently talk about their relationships with foreign law enforcement agencies including information sharing. For instance, FCPA enforcement agencies have stated:

“It is safe to say that we are cooperating with foreign enforcement on foreign bribery cases more closely today that at any time in history.”

“An international approach is being taken to combat an international criminal problem. We are sharing leads with our international law enforcement counterparts, and they are sharing them with us.”

Friday Roundup

By Mike Koehler on October 11, 2019 in Alejandro Yeatts, Biomet, Braskem SA, Compliance, Compliance Defense, Defamation, Foreign Law Enforcement Cooperation, Frank Roberto Chatburn Ripalda, Nancy Gougarty, Pemex, Related Civil Litigation, Serious Fraud Office, SFO, Westport Fuels Systems

Scratch that trial, scrutiny alert, affirmed, follow-up, Braskem-related, and across the pond. It’s all here in the Friday roundup.

Scratch That Trial

One of the FCPA trials scheduled this Fall (see here for the prior post) involved Frank Chatburn. As highlighted here, in April 2018 Frank Roberto Chatburn Ripalda (a dual United States and Ecuadorian citizen) was criminally charged for conspiring with others for making corrupt payments to PetroEcuador officials in order to obtain and retain contracts for Galileo (described as an Ecuadorian company that provided services in the oil and gas industry) from PetroEcuador.

SEC Chair Clayton Says That “In Many Areas Of The World, Our [FCPA] Work May Not Be Having The Desired Effect”

By Mike Koehler on September 10, 2019 in Enforcement Agency Policy, Enforcement Agency Speeches, Foreign Law Enforcement Cooperation, Has the FCPA Been Successful?, SEC

These pages have long posed the question of whether the Foreign Corrupt Practices Act has been successful in achieving its objectives. (See here for a recent law review article titled “Has the FCPA Been Successful in Achieving Its Objectives” – see also here for FCPA Flash podcast episodes on the topic).

These pages have also long posed the question of whether country exits in the aftermath of FCPA scrutiny or enforcement are a good thing (as the government often seems to suggest) or rather a bad thing. (See here for numerous posts).

Yesterday, in this speech, SEC Chairman Jay Clayton discussed the same topics and offered candid observations that seemingly conflict with much of the government’s FCPA enforcement rhetoric over the last several years.

“Frankly, If You Bring In A Couple Billion Dollars A Year, You Just Keep On Going,” And Other Musings From Former FCPA Prosecutors

By Mike Koehler on April 2, 2019 in Cash Cow, Foreign Law Enforcement Cooperation, Voluntary Disclosure

This Trace International Bribe, Swindle or Steal podcast is a recording of a recent panel discussion between former FCPA prosecutors Charles Duross (DOJ), Nat Edmonds (DOJ) and Richard Grime (SEC).

It is an informative listen on several levels including voluntary disclosure and international cooperation and set forth below are some of the more candid comments from the former FCPA prosecutors.

SEC Co-Director Of Enforcement Peikin On International Cooperation

By Mike Koehler on December 13, 2018 in Enforcement Agency Policy, Enforcement Agency Speeches, Foreign Law Enforcement Cooperation, SEC

Recently Steven Peikin (Co-Director of the SEC’s Enforcement Division) delivered this speech in which he talked about international cooperation and how it is “critical to the SEC’s civil law enforcement success” including the Foreign Corrupt Practices Act space.

In addition, Peikin stated that “vigorous enforcement of the FCPA remains a high priority for the SEC.”

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Friday Roundup

SEC Chair Clayton Says That “In Many Areas Of The World, Our [FCPA] Work May Not Be Having The Desired Effect”

“Frankly, If You Bring In A Couple Billion Dollars A Year, You Just Keep On Going,” And Other Musings From Former FCPA Prosecutors

SEC Co-Director Of Enforcement Peikin On International Cooperation

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