Top Menu

Foreign Official Reports Attempted Briber Leading To Enforcement Action

sigir

[This post is part of a periodic series regarding “old” FCPA enforcement actions]

The 2006 Foreign Corrupt Practices Act enforcement action against Faheem Mousa Salam had an unusual origin in that the foreign official Salam attempted to bribe – a senior Iraqi police official – reported the conduct to the Office of the Special Inspector General for Iraq Reconstruction (SIGIR). The police official then became a confidential informant leading to an undercover operation by SIGIR with an agent posing as a Procurement Officer for the Civilian Police Assistance Training Team (CPATT – a multinational organization tasked with training, mentoring and equipping the Iraq Police Force and responsible for ordering and supplying materials to the Iraqi Police Force).

The enforcement action is also notable in that Salam was prosecuted, plead guilty, and was sentenced to three years in prison for offering the bribe.

Continue Reading

From The Dockets

Judicial Decision

Updates in the FCPA prosecutions of Lawrence Hoskins and Frank Chatburn.

Hoskins

This previous post highlighted how Lawrence Hoskins (a U.K. national criminally charged with FCPA offenses in 2013) recently argued “enough is enough” as he seeks dismissal of the indictment based on violations of the Speedy Trial Act and his constitutional rights to a fair and speedy trial.

As reported here:

Continue Reading

Jury Convicts Baptiste And Boncy

Judicial Decision

As highlighted in this previous post, in 2017 (in connection with an undercover string) the DOJ unsealed criminal charges against Joseph Baptiste (a retired U.S. Army Colonel, practicing dentist, and founder / president of a Maryland-based Haitian focused non-profit) for alleged Haitian bribery.

As highlighted in this previous post, in 2018 the DOJ added criminal charges against Roger Boncy in connection with the same core conduct.

Unlike most individual FCPA defendants, Baptiste and Boncy put the DOJ to its burden of proof. As indicated in this recent DOJ release after a two-week jury trial, a federal jury in Boston found Baptiste guilty of one count of violating the Travel Act and one count of conspiracy to commit money laundering and Boncy guilty of one count of conspiracy to violate the FCPA and the Travel Act.

Continue Reading

Checking In On The Baptiste Enforcement Action

Baptiste

As highlighted in this prior post, in August 2017, in connection with an undercover sting, the DOJ announced that Joseph Baptiste (pictured – a retired U.S. Army Colonel, practicing dentist, and former founder/president of a Maryland-based Haitian focused non-profit) was criminally charged “for his alleged role in a foreign bribery and money laundering scheme in connection with a planned $84 million port development project in Haiti.”

Baptiste’s trial is scheduled to begin in early June and this post checks in on the enforcement action.

Continue Reading

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”

LG

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.”

Continue Reading

Powered by WordPress. Designed by WooThemes