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Friday Roundup

By on May 24, 2019 in Arbitration Issues, Biomet, Compliance, Detelina Subeva, DOJ Evaluation of Corporate Compliance Programs, Major League Baseball, Vantage Drilling, Whistleblowers, Zimmer Holdings
Roundup

Whistleblower award, interesting observations, scrutiny update, why in the world, you lose some and you win some, and guilty plea. It’s all here in the Friday roundup.

Whistleblower Award

According to this report, “a former Brazilian surgeon who blew the whistle on a medical device company that allegedly bribed doctors to win business will get a $4.5 million award from U.S. regulators, according to his lawyers. The surgeon will get the money for playing a crucial role in helping the SEC uncover a bribery scandal at Biomet Inc. that spanned the globe. (See here for the SEC release).

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Issues To Consider From The Vantage Drilling Enforcement Action

By on November 27, 2018 in Disgorgement, Gray Cloud, Inability to Pay, Kokesh, Non-Bribery Charged Disgorgement, Vantage Drilling
Issues

This previous post went in-depth into the rather unusual Vantage Drilling Foreign Corrupt Practices Act enforcement action and this post continues the analysis by highlighting additional issues to consider.

Timeline

As highlighted here, in July 2015 (or shortly thereafter) Vantage Drilling voluntarily disclosed to the DOJ/SEC. Thus, from start to finish the company’s FCPA scrutiny lasted approximately 3.5 years. While this is below recent averages of approximately 4.5 years, it is still too long for FCPA scrutiny to last particularly since Vantage Drilling, in the words of the SEC:

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Vantage Drilling Resolves Rather Unusual $5 Million FCPA Enforcement Action

By on November 20, 2018 in 2018 Enforcement Actions, Brazil, Hamylton Padilha, Internal Controls, Nobu Su, Oil and Gas Industry, SEC Enforcement Action, Vantage Drilling
vantagedrilling

Yesterday, the SEC announced this rather unusual Foreign Corrupt Practices Act enforcement action against Vantage Drilling.

What made it rather unusual is that the administrative action only found violations of the FCPA’s internal controls provisions concerning its unique relationship with a former outside director and shareholder that “created a risk that [the company] was providing or reimbursing funds that [the Director] intended to use to make improper payments to officials at Petrobras” in connection with obtaining a drilling services contract.

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Friday Roundup

By on November 9, 2018 in Cognizant Technology Solutions, Dmitrij Harder, FCPA Jurisprudence, FCPA Sentences, Goldman Sachs, Vantage Drilling
Roundup

Affirmed, very distressing, scrutiny updates, and for the reading stack. It’s all here in the Friday roundup.

Affirmed

As highlighted in this previous post, in July 2017 Dmitrij Harder was sentenced to 60 months (5 years) in federal prison and also ordered to forfeit $1.9 million after pleading guilty to two counts of violating the FCPA for “bribing an official at the European Bank for Reconstruction and Development (EBRD).”

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Friday Roundup

By on July 20, 2018 in Caesars Entertainment, Chi Ping Patrick Ho, FCPA Statistics, FIFA, Imagina Media, Jurisdiction, Luis Carlos De Leon Perez, Media Reporting, Media Reporting About the FCPA, MGM Resorts, Paul Bragg, US Imagina, Vantage Drilling
Roundup

Motion to dismiss denied, scrutiny alert, guilty plea, reverse, FCPA resolution template, perplexing, funny, and fake news. It’s all here in the Friday roundup.

Motion to Dismiss Denied

As highlighted in this prior post, in November 2017 the DOJ announced that Chi Ping Patrick Ho (of Hong Kong, China) and Cheikh Gadio (of Senegal) were criminally charged with conspiring to violate the FCPA, violating the FCPA, conspiring to commit international money laundering, and committing international money laundering.

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