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Friday Roundup

Scrutiny alert, investor wants answers, sentenced, to Bribery Act Inc., compliance, and for the reading stack.

It’s all here in the Friday roundup.

Scrutiny Alert

Raytheon recently disclosed [1]:

“Raytheon has received a subpoena from the Securities and Exchange Commission (SEC) seeking information in connection with an investigation into whether there were improper payments made by Thales-Raytheon Systems (TRS), Raytheon or anyone acting on their behalf in connection with TRS or Raytheon contracts in certain Middle East countries since 2014. Raytheon maintains a rigorous anti-corruption compliance program, is cooperating fully with the SEC’s inquiry, and is examining whether there has been any conduct that is in violation of Raytheon policy. At this point there is no ability to predict the outcome of the SEC’s inquiry. Based on the information available to date, however, we do not believe the results of this inquiry will have a material adverse effect on our financial condition, results of operations or liquidity.”

Investor Wants Answers

In the aftermath of the Ericsson enforcement action (see here [2]), Folksam (one of the largest insurance companies in Sweden and a substantial investor in Ericsson) wants answers. In this release [3], Folksam wants answers to the following questions:



As highlighted here [5], Jose Melquiades Cisneros Alarcón (criminally charged in connection with a PetroEcuador bribery scheme, but who pleaded guilty “only” to money laundering charges) was recently sentenced to 20 months in prison. “The sentence departs significantly from the guidelines of 108 to 135 months, reflecting Cisneros’ cooperation with prosecutors, his low-level role in the scheme, and the sentences of other defendants caught up in the PetroEcuador bribery scandal.”

de Silva to Bribery Act Inc.

Simmons + Simmons recently announced [6] that Camilla de Silva (until recently the Co-Head of Fraud and Corruption at the United Kingdom Serious Fraud Office) has joined the firm. As stated in the release: “Her work for the SFO has involved some of the largest global and British companies across a wide range of industries and sectors from pharma to finance, and most recently she has been instrumental in negotiating the landmark Airbus DPA.” (See here [7] for the FCPA Flash podcast episode with de Silva).


In this publication [8] GoodCorporation uses its Framework on Bribery & Corruption to test the strength and effectiveness of corporate anti-bribery and corruption procedures.

For the Reading Stack

An interesting piece here [9] by Kirkland attorneys concerning the intersection of project finance and corruption allegations.

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Connect [10]