Gol Intelligent Airlines Archives

Issues To Consider From The Gol Enforcement Action

By Mike Koehler on September 26, 2022 in Causation, Competitor Companies Benefiting From Bribery, Foreign Company “Bribing” Its “Domestic” Officials, Gol Intelligent Airlines, Gray Cloud, Jurisdiction, OECD

This post highlighted the recent net $38.1 million Foreign Corrupt Practices Act enforcement action against Gol Linhas Aereas Inteligentes S.A. (Gol) – an airline headquartered in Sao Paulo, Brazil with shares traded on the New York Stock Exchange – for bribing Brazilian officials.

This post highlights additional issues to consider from the enforcement action.

Timeline

As highlighted in this prior post, Go’s FCPA (and related) scrutiny began in late 2016.

Thus from start to finish, Gol’s FCPA scrutiny lasted an approximate six years.

Scrutiny Alerts and Updates

By Mike Koehler on May 8, 2017 in Amec Foster Wheeler, BRF, Cognizant Technology Solutions, Gol Intelligent Airlines, Graña y Montero S.A.A., Investigative Fees, KT Corp., Misonix, Offensive Use of FCPA, Related Civil Litigation, Societe Generale

Late April or early May is when foreign issuers tend to file Form 20-F’s with the SEC and as highlighted in this post several foreign issuers from Brazil, Peru, the U.K. and South Korea disclosed Foreign Corrupt Practices Act scrutiny.

But first, Cognizant Technology Solutions appears to continue to “boil the ocean” in terms of pre-enforcement action professional fees and expenses and Misonix is hit with a civil lawsuit connected to its FCPA scrutiny.

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Issues To Consider From The Gol Enforcement Action

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