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Scrutiny Alerts And Updates

scrutiny alert


Netherlands-based ING NV, a company with shares listed on the New York Stock Exchange, recently disclosed:

“ING Bank is the subject of criminal investigations by Dutch authorities regarding various requirements related to the on-boarding of clients, money laundering and corrupt practices. ING Groep has also received related information requests from U.S. authorities. ING Groep and ING Bank are cooperating with such ongoing investigations and requests. It is currently not feasible to determine how the ongoing investigations and requests may be resolved or the timing of any such resolution, nor to estimate reliably the possible timing, scope or amounts of any resulting fines, penalties and/or other outcome, which could be significant.”

According to this report, quoting a spokesperson from the Dutch prosecutors office, “The subject of the investigation is, among others, unusual payments by VimpelCom to the company of an Uzbek government official.” The report further states:

“ING’s involvement was disclosed publicly in documents filed in U.S. District Court for the Southern District of New York in February 2016. U.S. prosecutors said $800 million in bribes were paid to shell companies owned by a high-ranking official in Uzbekistan related to late President Islam Karimov. The U.S. court documents showed that $184 million of the payments originated from ING Bank.”

See here and here for prior posts regarding VimpelCom’s FCPA enforcement action.


According to this report, Australia-based engineering company Cardno is under investigation for allegations “of bribery in up to five bids, including a hydro-electric project, in a scheme using US banks” and that the company “had notified Australian and US authorities, and the firm noted some kind of sanction was “probable”.”

U.K. SFO-Related

According to this Wall Street Journal Risk & Compliance Journal report:

“There’s a renewed urgency at the U.K.’s Serious Fraud Office to resolve the various investigations of bribery and corruption at large global companies on its books over the next year, before David Green hands in his security badge in April 2018. The agency’s director since 2012, Mr. Green will leave the SFO next April and he is keen to have the bulk of the major cases under investigation by the SFO–which include Airbus Group SE, Barclays Bank PLC, GlaxoSmithKline PLC, Tesco PLC, and Unaoil–well on their way to some resolution. “I’d like certainly to resolve the big investigations that I’ve started…to bring them to the point where a charging decision has been made,” Mr. Green said in an interview with Risk & Compliance Journal. Airbus and Tesco have said they are cooperating with the investigations; the SFO is expected to charge Barclays in coming weeks; Unaoil is legally challenging the SFO’s case; Glaxo said in its annual report that it has responded to the SFO’s investigation.”


Regarding the long-standing legal proceedings against Juthamas Siriwan, the “foreign official” implicated in the Gerald and Patricia Green Thai Film Festival FCPA enforcement actions (see numerous priors posts under this subject matter tag), the Bangkok post reports:

“The National Anti-Corruption Commission (NACC) has decided to seize the assets of Juthamas Siriwan, a former Tourism Authority of Thailand (TAT), for being unusually rich. The seizure came long after a film festival bribery case in the US in which she was accused of taking bribes from a Los Angeles film-making couple who were awarded a 60-million-baht contract to host the annual Bangkok International Film Festival between 2003 and 2006. Hollywood producers Gerald and Patricia Green allegedly paid her about 8 million (63.3 million baht) to help secure the film festival. The Greens were convicted in 2009 and sentenced to six months in jail. Mrs Juthamas was indicted by the Office of the Attorney-General in August 2015, and the Criminal Court will rule on the case next Wednesday. Nitiphan Prachuabmoh, the NACC official in charge of foreign affairs, said on Friday a panel had found her unusually rich by using her position to gain wealth. Her assets will be confiscated including those she had allegedly transferred to her daughter Jittisopha, the official said. The NACC has contacted US authorities to freeze the assets and will ask the US to transfer them to Thai state coffers under the United Nations Convention against Corruption in 2004 and other agreements, according to Mr Nittiphan.”

Free 90 Minute 2017 FCPA Year In Review Video

A summary of every corporate enforcement action; notable statistics and issues to consider; compliance take-away points; and enforcement agency and related developments. Click below to view the engaging video tutorial.


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