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Potpourri

Potpourri

Ericsson

As highlighted in this prior post, in 2019 Ericsson (a Swedish telecom company with American Depositary Shares traded in the U.S.) resolved a $1.06 billion FCPA enforcement action concerning conduct in Djibouti, China, Vietnam, Kuwait, Indonesia, and Saudi Arabia.

As part of the resolution, Ericsson was required to engage an independent compliance monitor for a three-year period.

In late 2022, Ericsson announced “that it has agreed with the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to extend the term of the Company’s Independent Compliance Monitor for one year, to June 2024.” (See here for the prior post).

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Petrofac Resolves Bribery Act Enforcement Action

Petrofac

Petrofac (a U.K. based oil and gas company with ADRs registered with the SEC) has been under scrutiny since 2016 regarding its relationship with Unaoil. (See here for the prior post).

In 2019, the U.K. Serious Fraud Office announced that David Lufkin (the former Global Head of Sales for Petrofac International Ltd.) pleaded guilty to eleven counts of bribery related to “the making of corrupt offers to influence the award of contracts to Petrofac worth in excess of USD $730 million in Iraq and in excess of USD $3.5 billion in Saudi Arabia.” (See here).

Recently, the SFO announced that it has “secured the conviction of Petrofac Limited for seven separate counts of failure to prevent bribery between 2011 and 2017.”

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Checking In On Petrofac

Petrofac

Petrofac (a U.K. based oil and gas company with ADRs registered with the SEC) has been under scrutiny since 2016 regarding its relationship with Unaoil. (See here for the prior post).

In 2019, the U.K. Serious Fraud Office announced that David Lufkin (the former Global Head of Sales for Petrofac International Ltd.) pleaded guilty to eleven counts of bribery related to “the making of corrupt offers to influence the award of contracts to Petrofac worth in excess of USD $730 million in Iraq and in excess of USD $3.5 billion in Saudi Arabia.” (See here).

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Friday Roundup

Roundup

Good lord, scrutiny alert and updates, across the pond, and for the reading stack. It’s all here in the Friday roundup.

Good Lord

Here is how Rep. Jackie Speier (an individual with a law degree) described the Foreign Corrupt Practices Act on a recent CNN program – “It is a requirement that anyone doing business with a foreign entity make sure that none of the money that comes into a project has been laundered.”

Good lord, get it right or stop talking about the FCPA.

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Friday Roundup

Roundup

Across the pond, the big picture, ripple, a muddy mess, to FCPA Inc., scrutiny alert, silly and erroneous, misleading, ISO 37001 related, and for the reading stack.

It’s all here in the Friday roundup.

Across the Pond

In this recent speech, David Green (Director of the U.K. Serious Fraud Office) said the U.K. Bribery Act is “regarded as a gold standard internationally” and, as further proof that so-called enforcement competition does exist, he stated:

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