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Issues To Consider From The Trafigura Enforcement Action

Issues

This previous post covered the net $100.2 million FCPA enforcement action against Trafigura concerning conduct in Brazil.

This post highlights additional issues to consider.

Timeline

Trafigura was under FCPA scrutiny since at least early 2019 (see here from the prior post).

Thus, from start to finish the company was under scrutiny for approximately 5 years.

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Issues To Consider From The Gunvor Enforcement Action

Issues

This recent post highlighted the net $474.4 million Foreign Corrupt Practices Act enforcement action against Gunvor (a Swiss-based energy trading company – a subsidiary of Gunvor Group Ltd., a multinational energy commodities trading company registered in Cyprus).

In summary fashion, the DOJ alleged that between 2012 and 2020 Gunvor, through various managers, “knowingly and willfully conspired and agreed with others to corruptly offer and pay bribes to, and for the benefit of, Ecuadorian officials to secure improper advantages in order to obtain and retain business from Petroecuador in connection with the purchase and sale of oil products through contracts between Petroecuador” and state-owned energy trading companies based in Asia.

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

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Issues To Consider From The SAP Enforcement Action

Issues

This previous post highlighted the recent FCPA enforcement action against SAP based on conduct in South Africa, Indonesia, Malawi, Kenya, Tanzania, Ghana, and Azerbaijan.

This post highlights additional issues to consider.

Timeline

As highlighted in this previous post, in mid-2017 SAP disclosed that it was under FCPA scrutiny concerning its business practices in South Africa.

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Like Prior Years, The Gray Cloud Of FCPA Scrutiny Lasted Too Long In 2023

Gray Cloud

This recent post highlighted the origins of corporate Foreign Corrupt Practices Act enforcement actions in 2023.

Continuing with the 2023 FCPA statistical feast, this post follows the chronology of scrutiny to enforcement and highlights one of the most troubling policy issues when it comes to FCPA enforcement.

That is – FCPA scrutiny simply lasts too long. Specifically, as highlighted below, 5 years was the approximate median length of time companies that resolved FCPA enforcement actions in 2023 were under scrutiny.

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Issues To Consider From The Tysers And H.W. Wood Enforcement Actions

Issues

This previous post discussed the related DOJ Foreign Corrupt Practices Act enforcement actions against United Kingdom reinsurance brokers Tysers Insurance Brokers Limited (acquired by AUB Group in 2022) and H.W. Wood Limited for “participation in a corrupt scheme to pay bribes to Ecuadorian government officials.”

This post highlights additional issues to consider.

Timeline

AUB previously disclosed in 2022.

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