Libya Archives - FCPA Professor

SNC-Lavalin Pleads Guilty In Canada’s Most Significant Foreign Corruption Case To Date

By Mike Koehler on December 30, 2019 in Canada, Libya, SNC Lavalin, Uncategorized

Numerous prior posts dating back to 2012 (see here for the subject matter tag) have discussed SNC-Lavalin Group’s (a Montreal-based engineering, procurement and construction services company) scrutiny under Canada’s FCPA-like law, the Corruption of Foreign Public Officials Act (CFPOA).

After years of pouting that it was not being treated fairly (see here among other posts), SNC-Lavalin recently resolved a $280 million CFPOA enforcement action.

The below guest post from McCarthy Tetrault attorneys John Boscariol, Andrew Matheson and Robert Glasgow summarizes the enforcement action and its broader implications.

DOJ Announces Guilty Pleas By Former Unaoil Executives

By Mike Koehler on October 31, 2019 in 2019 Enforcement Actions, Algeria, Angola, Azerbaijan, Congo, Cyrus Ahsani, DOJ Enforcement Action, Foreign Nationals, Foreign Official, Foreign Officials, Gaining Access to Confidential Documents, Iran, Iraq, Kazakhstan, Libya, Oil and Gas Industry, Saman Ahsani, Steven Hunter, Syria, Unaoil, Uncategorized

Yesterday, the DOJ announced that Cyrus Ahsani and Saman Ahsani (the former CEO and Chief Operations Officer of Monaco-based Unaoil) pleaded guilty in March 2019 to one count of conspiracy to violate the FCPA for their roles in a scheme to corruptly facilitate millions of dollars in bribe payments to officials in multiple countries. The DOJ also announced that Steven Hunter (a former business development manager at Unaoil) pleaded guilty in August 2018 to one count of conspiracy to violate the FCPA.

Prior Foreign Corrupt Practices Act enforcement actions against Rolls-Royce and SBM Offshore (see here and here) involved, in whole or in part, Unaoil and the Ahsani information refers to approximately 25 other companies including approximately ten U.S. based issuers. Thus, it is likely that additional FCPA enforcement actions involving, in whole or in part, Unaoil will be forthcoming.

SEC Finally Announces Its FCPA Enforcement Action Against Legg Mason

By Mike Koehler on August 27, 2018 in 2018 Enforcement Actions, Disgorgement, Financial Services Industry, Kokesh, Legg Mason, Libya, SEC Enforcement Action

Prior posts here and here highlighted the DOJ’s June FCPA enforcement action against Legg Mason regarding business conduct in Libya. It was noted in the prior post that FCPA enforcement actions against issuers that involve a DOJ and SEC component are almost always announced on the same day. Yet for some reason, back in June the i’s were not dotted or the t’s crossed at the SEC and the DOJ’s June enforcement action clearly had a placeholder for the forthcoming SEC prong.

That happened earlier today as the SEC finally announced its enforcement action.

Issues To Consider From The Legg Mason Enforcement Action

By Mike Koehler on June 6, 2018 in Books and Records, Disgorgement, Foreign Official, Internal Controls, Kokesh, Legg Mason, Libya, Root Causes, Statute of Limitations

This previous post went in-depth into the DOJ’s recent Foreign Corrupt Practices Act enforcement action against Legg Mason. This post continues the analysis by highlighting additional issues to consider.

SEC Enforcement Action Is Forthcoming

Given Legg Mason’s recent disclosure (see here for the prior post), it was a bit of a surprise that this week’s enforcement action included only a DOJ component. FCPA enforcement actions against issuers that involve a DOJ and SEC component are almost always announced on the same day.

Legg Mason Also Ponies Up $64 Million To Resolve FCPA Enforcement Action Concerning Conduct In Libya That Occurred 9-14 Years Ago By “Only Two Mid-To-Lower Level Employees Of A Subsidiary”

By Mike Koehler on June 4, 2018 in 2018 Enforcement Actions, Anything of Value, DOJ Enforcement Action, Financial Services Industry, ISO 37001, Legg Mason, Libya, Third Parties, Travel and Entertainment, Undercover Investigations

A few hours after the DOJ announced a net $293 million Foreign Corrupt Practices Act enforcement action against Société Générale S.A concerning conduct in Libya that occurred 9-14 years ago (see here for the prior post), the DOJ also announced that investment management firm Legg Mason also agreed to pony up $64 million to resolve a related enforcement action.

Pursuant to a three-year NPA, Legg Mason agreed to pay $64 million based on the conduct of “only two mid-to-lower level employees of a subsidiary of the company” (specifically Permal Group Ltd.). According to the DOJ: “Permal’s financial statements were consolidated into Legg Mason’s financial statements and they participated in a net revenue sharing arrangement, and all employees of Permal were subject to Legg Mason’s code of conduct.”

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SNC-Lavalin Pleads Guilty In Canada’s Most Significant Foreign Corruption Case To Date

DOJ Announces Guilty Pleas By Former Unaoil Executives

SEC Finally Announces Its FCPA Enforcement Action Against Legg Mason

Issues To Consider From The Legg Mason Enforcement Action

Legg Mason Also Ponies Up $64 Million To Resolve FCPA Enforcement Action Concerning Conduct In Libya That Occurred 9-14 Years Ago By “Only Two Mid-To-Lower Level Employees Of A Subsidiary”

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