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Friday Roundup


Convicted, sentenced, to FCPA Inc. and for the reading stack. It’s all here in the Friday Roundup.


As noted in this DOJ release: “[Donville Inniss] a former member of the Barbados Parliament, who also served as the Minister of Industry of Barbados, was found guilty [of two counts of money laundering and one count of conspiracy to commit money laundering] by a federal jury for his role in a scheme to launder bribes paid to him by executives of the Insurance Corporation of Barbados Limited (ICBL).”

As stated in the release:

“According to the evidence presented at trial, in 2015 and 2016, Inniss took part in a scheme to launder into the United States approximately $36,000 in bribes that he received from high-level executives of ICBL.  At the time, Inniss was a member of the Parliament of Barbados and the Minister of Industry, International Business, Commerce, and Small Business Development of Barbados.  The trial evidence demonstrated that, in exchange for the bribes, Inniss leveraged his position as the Minister of Industry to enable ICBL to obtain two insurance contracts from the Barbados government to insure over $100 million worth of government property.  To conceal the bribes, Inniss arranged to receive them through a U.S. bank account in the name of his friend’s dental company, which had an address in Elmont, New York.  The trial evidence further showed that Inniss used a personal email account to communicate with an executive from ICBL in connection with the bribe payments and the laundering of the money through the dental company in New York.”

See here for the prior post regarding the Insurance Corporation of Barbados Limited.


The S.D. of Florida continues to be a jurisdiction that hands down stiff FCPA sentences. As noted in this DOJ release

“[Juan Jose Hernandez Comerma (Hernandez)] former general manager and partial owner of a Florida-based energy company was sentenced to 48 months in prison … for his role in a scheme to corruptly secure contracts from Venezuela’s state-owned and state-controlled energy company, Petroleos de Venezuela S.A. (PDVSA).”

According to the release, Hernandez was further ordered to pay a fine of $127,000 and forfeit $3 million.

See this prior post for the underlying enforcement action.

Miner to FCPA Inc.

Like so many other DOJ or SEC enforcement officials with discretion over FCPA enforcement or policy, former Deputy Assistant Attorney General of the Criminal Division Matthew Miner has joined a law firm to focus “on matters relating to white collar enforcement and compliance, the Foreign Corrupt Practices Act (FCPA), crisis management, congressional inquiries, and internal investigations.”

As stated in this Morgan Lewis release: “His more than 10 years of US government experience, including his most recent service in a senior role in the DOJ’s Criminal Division, is a valuable asset to our clients facing enforcement investigations and actions, congressional inquiries, and challenging crisis management matters.”

Reading Stack

Two of the best law firm FCPA publications are Gibson Dunn’s Year-End FCPA Update and Shearman & Sterling’s Recent Trends and Patterns in the Enforcement of the FCPA. Put them both on your reading stack.

See here for a recent Corporate Crime Reporter Q&A with Winston & Strawn partner Pam Davis on FCPA monitors. As noted in the article, Davis has been a monitor in connection with three FCPA enforcement actions.

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