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Taking A Helicopter To A L.A. Lakers Game


In June 2023, the DOJ announced an enforcement action against Amadou Kane Diallo (pictured – a Senegalese national and California resident who was the CEO of two California-based companies: Virtual Advisors LLC and Liquide Inc).

As stated in the DOJ release:

“Diallo allegedly solicited investments in his companies from at least 11 individuals for purported business opportunities in technology, health care, real estate, home ownership, and service to the African diaspora. Diallo allegedly made various false representations, including that investor funds would be spent to further investors’ interests, or not be spent at all, and instead used as “skin in the game” to attract institutional investors. Diallo is also alleged to have lied to potential investors, claiming that he had raised hundreds of millions of dollars for another investment firm and its real estate investment fund when, in fact, he had never raised any such funds.

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Fresenius Medical Care Pays Approximately $232 Million To Resolve Its Long-Standing FCPA Scrutiny


German healthcare firm Fresenius Medical Care AG (a company with American Depositary Receipt shares traded on the NYSE) has been under FCPA scrutiny since 2012 (no that is not a typo).

Today the DOJ and SEC announced (here and here) an approximate $232 million enforcement action ($84.7 million to the DOJ and $147 million to the SEC) against the company for alleged bribery schemes involving physicians and other healthcare personnel in Angola, Saudi Arabia, Morocco, Spain, Turkey, Gabon, Benin, Burkina Faso, Senegal, Ivory Coast, Niger, Cameroon China, Serbia, Bosnia, and Mexico.

While not specified in any of the resolution documents, the DOJ’s non-prosecution agreement and SEC’s administrative order make generic reference to the Angola and Saudi Arabia conduct involving ‘agents and employees utiliz[ing] the means and instrumentalities of U.S. interstate commerce, including the use of internet-based email accounts hosted by numerous service providers located in the United States.”

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