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Potpourri

Potpourri

Guilty Plea

This recent post highlighted the DOJ’s money laundering case against Luis Enrique Martinelli Linares (a citizen of Panama and Italy) and his brother Ricardo Alberto Martinelli Linares (also a citizen of Panama and Italy), for “participating 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.

Luis recently pleaded guilty and yesterday the DOJ announced that Ricardo did as well.

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Thoughts On The JPMorgan Whistleblower Complaint

Thoughts

This recent post highlighted the whistleblower complaint filed by a former employee of JPMorgan (Shaquala Williams) in connection with the 2016 Foreign Corrupt Practices Act enforcement action against the company.

As described in the prior post, the JPMorgan enforcement action was based on alleged improper hiring and internship practices that the U.S. government labeled bribery and corruption. The DOJ portion was resolved through a three year non-prosecution agreement involving JPMorgan Securities (Asia Pacific) Limited (“JPMorgan-APAC), a wholly subsidiary of JP Morgan, which involved a variety of requirements and undertakings imposed upon the company – as is typical in resolving FCPA enforcement actions.

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Former JPMorgan Employee Files Whistleblower Complaint In Connection With 2016 FCPA Enforcement Action

whistleb

As highlighted here and here, in November 2016 JPMorgan (and related entities) resolved a $202.6 million DOJ and SEC Foreign Corrupt Practices Act enforcement action based on its alleged improper hiring and internship practices that the U.S. government has labeled bribery and corruption.

The DOJ action was resolved through a three year non-prosecution agreement involving JPMorgan Securities (Asia Pacific) Limited (“JPMorgan-APAC), a wholly subsidiary of JP Morgan, which involved a variety of requirements and undertakings imposed upon the company – as is typical in resolving FCPA enforcement actions.

Recently, Shaquala Williams (a former employee of JPMorgan in New York city) filed a civil complaint in federal court (S.D.N.Y) against JPMorgan. In summary fashion, the complaint alleges:

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Hong Kong Court Finds Former JP Morgan Exec Not Guilty Of Bribery In Connection With “Sons And Daughters” Program

not guilty

As highlighted in prior posts here and here, in 2016 JP Morgan resolved a $202.6 million Foreign Corrupt Practices Act enforcement action against J.P. Morgan (and a related entity) based on its alleged improper hiring and internship practices that the U.S. government labeled bribery and corruption.

According to the DOJ, “the so-called Sons and Daughters Program was nothing more than bribery by another name. Awarding prestigious employment opportunities to unqualified individuals in order to influence government officials is corruption, plain and simple.”

Like nearly all modern corporate FCPA enforcement actions, the JP Morgan matter was not subjected to any meaningful judicial scrutiny.

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Friday Roundup

Roundup

Sentenced, just saying, scrutiny alerts and updates, fallout, and what’s the difference? It’s all here in the Friday roundup.

Sentenced

As highlighted in this prior post, earlier this year Frank James Lyon (the owner of Lyon Associates Inc. – a privately held engineering and consulting company headquartered in Hawaii) pleaded guilty to violating the Foreign Corrupt Practices Act (based on things of value provided to officials in the Federated States of Micronesia) as well as paying bribes to an agent of an organization receiving federal funds (based on things of value provided to officials with a Hawaii governmental agency – State Agency).

As highlighted in this DOJ release, Lyon was recently sentenced to 30 months in prison.

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