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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.”

Friday Roundup

By Mike Koehler on September 8, 2017 in Collateral Effects, Declination Decisions, Enforcement Competition, FCPA Inc., FCPA Statistics, ISO 37001, Petrofac, Rolls-Royce, Serious Fraud Office, U.K. Bribery Act, Undercover Investigations, United Kingdom

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:

In Connection With Undercover Sting, DOJ Unseals Criminal Charges Against Joseph Baptiste For Alleged Haitian Bribery

By Mike Koehler on August 30, 2017 in 2017 Enforcement Actions, DOJ Enforcement Action, Haiti, Individual Enforcement Action, Undercover Investigations

Yesterday, 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.”

According to this FBI Agent affidavit in support of the criminal complaint, during the time period relevant to the complaint Baptiste served as the president of an entity headquartered in Maryland that purported to be a non-profit organization with the stated mission of helping the impoverished in Haiti” and further served as a member of the board of directors of Company A, an LLC organized under Delaware Law. According to the affidavit, Company A’s mission was to promote a port development project in an area of Haiti known as Moles Saint Nicolas.

DOJ Announces Criminal Charges And Plea Agreements In Connection With Mexican Aviation Bribery Scheme

By Mike Koehler on December 28, 2016 in 2016 Enforcement Actions, Aviation Industry, Daniel Perez, DOJ Enforcement Action, Douglas Ray, Ernesto Hernandez Montemayor, FCPA Related Charges, Hunt Pan Am Aviation, Individual Enforcement Action, Kamta Ramnarine, Mexico, Ramiro Ascencio Nevarez, Undercover Investigations, Victor Valdez

This recent post highlighted the many Foreign Corrupt Practices Act enforcement actions involving the aviation industry.

Add another to this long list as yesterday, the DOJ announced that criminal charges “were unsealed against six individuals, all of whom have pleaded guilty for their involvement in schemes to bribe Mexican officials in order to secure aircraft maintenance and repair contracts with government-owned and controlled entities, and two for conspiring to launder the proceeds of the schemes.”

The criminal FCPA conspiracy charges were against four individuals: Daniel Perez, Kamta Ramnarine, Victor Valdez, and Douglas Ray.

Friday Roundup

By Mike Koehler on September 9, 2016 in AstraZeneca, Australia, Cisco, Deferred Prosecution Agreements, Fine / Penalty Issues, Foreign Issuers, LAN / LATAM Airlines, Louis Berger International, Related Civil Litigation, Richard Hirsch, Undercover Investigations, United Kingdom

No comment, scrutiny alert, when the obvious is not so obvious, quotable, undercover, follow-up, and for the reading stack. It’s all here in the Friday roundup.

No Comment

The recent FCPA enforcement action against Chile-based LAN Airlines (in which the company paid $22 million to resolve DOJ and SEC enforcement actions concerning an alleged payment to resolve an Argentina labor dispute) suggested that both Argentine and Chilean law enforcement officials had commenced investigations of the conduct approximately five years ago.

I’ve tried to find information in the public domain regarding these apparent law enforcement investigations but have generally struck out.

For instance, I contacted LAN’s investor relations office and posed the following question:

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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”

Friday Roundup

In Connection With Undercover Sting, DOJ Unseals Criminal Charges Against Joseph Baptiste For Alleged Haitian Bribery

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