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Former Corsa Coal VP And Head Of International Sales Pleads Guilty To Egypt Bribery Scheme

Cushmore

Corsa Coal Corp. is a publicly traded Pennsylvania-based coal mining company focused on the production and sales of metallurgical coal, an essential ingredient in the production of steel. It’s core business is producing and selling metallurgical coal to domestic and international steel and coke producers.

Between 2016 and 2020, Frederick Cushmore Jr. (pictured) was employed by Corsa in various international sales positions including Vice-President, Head of International Sales. (See here for Corsa’s 2018 press release announcing Cushmore’s promotion. In the release, Corsa’s CEO stated: “We are thrilled to … provide Fred with a well-deserved promotion.”

Recently, Cushmore was criminally charged and plead guilty to a conspiracy charge to violate the FCPA’s anti-bribery provisions in connection with a bribery scheme in Egypt.

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Many FCPA Enforcement Actions Involve Gaining Access To Confidential Information

confidential

In several Foreign Corrupt Practices Act enforcement actions, the end result of things of value being offered or provided to alleged “foreign officials” is the company gaining access to confidential documents in the government’s possession.

Which ones?

This post summarizes the nearly twenty FCPA enforcement actions which fit the above description in whole or in part (in addition to this week’s FCPA enforcement action against Amec Foster Wheeler and related entities).

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Issues To Consider From The Amec Foster Wheeler / John Wood Group Enforcement Action

Issues

This prior post highlighted the net $17.7 million FCPA enforcement action against U.K. companies Amec Foster Wheeler Energy, which was acquired by Amec Plc in 2014, which in turn, was acquired by John Wood Group Plc in 2017.

This post continues the analysis by highlighting additional issues to consider.

Timeline

As highlighted in this previous post, in Spring 2017 the company disclosed:

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U.K. Companies Resolve Net $17.7 Million FCPA Enforcement Action Concerning Conduct In Brazil

WoodFoster

Approximately 7-10 years ago, a U.K. corporation (#1) engaged in alleged improper conduct with alleged Brazilian officials largely through a Brazilian intermediary company with the assistance of an Italian agent. Approximately 7 years ago, a different U.K. corporation (#2) acquired U.K. corporation #1 and then approximately 4 years ago another U.K. corporation (#3) acquired U.K. corporation #2.

And then, the U.S. government brought an FCPA enforcement action against U.K. corporation #1 because, at one time, the company had shares traded on NASDAQ – even though in connection with the same core conduct the U.K. Serious Fraud Office and Brazil law enforcement also brought an enforcement action.

That pretty much sums up last Friday’s net $17.7 million FCPA enforcement action against Amec Foster Wheeler Energy, which was acquired by Amec Plc in 2014, which in turn, was acquired by John Wood Group Plc in 2017.

The enforcement action was the first corporate FCPA enforcement action of the Biden administration and closed the approximate six month gap in corporate FCPA enforcement.

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Issues To Consider From The Vitol Enforcement Action

Issues

This prior post highlighted the net $90 million Foreign Corrupt Practices Act enforcement action against Vitol for conduct in Brazil, Ecuador and Mexico. This prior post took a closer look at the net $28.8 million enforcement action brought by the Commodity Futures Trading Commission based on the same core conduct.

This post continues the analysis by additional issues to consider from the FCPA enforcement action.

Gaining Access to Confidential Information

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