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SEC charges global software company SAP $100 million for FCPA violations

The SEC’s order finds that SAP, whose American Depositary Shares are listed on the New York Stock Exchange, violated the FCPA by employing third-party intermediaries and consultants from at least December 2014 through January 2022 to pay bribes to government officials to obtain business with public sector customers in the seven countries mentioned above. According to the SEC’s order, SAP inaccurately recorded the bribes as legitimate business expenses in its books and records, despite the fact that certain of the third-party intermediaries could not show that they provided the services for which they had been contracted. The SEC’s order finds that SAP failed to implement sufficient internal accounting controls over the third parties and lacked sufficient entity-level controls over its wholly owned subsidiaries…

CFTC orders Freepoint Commodities to pay $91m for fraudulent scheme to misappropriate material non-public information

The fraudulent and deceptive conduct spanned from 2012 to 2018 and involved unlawful misconduct designed to obtain material non-public information from a South American state-owned enterprise in connection with the purchase and sale of fuel oil. The order requires Freepoint to pay more than $91m in civil monetary penalties and disgorgement…

GRECO calls on the United States to pursue its efforts to promote the integrity of persons entrusted with top executive functions, and as regards the personnel of the FBI

GRECO publishes detailed Fifth Round evaluation of corruption risks in the executive branch of the USA.

US Treasury sanctions former Guatemalan government official for engaging in public corruption

Luis Miguel Martinez Morales (Martinez) has been sanctioned for his role in corruption in Guatemala wherein he engaged in widespread bribery schemes, including schemes related to government contracts.

US DoJ settles with 2 British Reinsurance brokers over Ecuador bribes

Tysers Insurance Brokers Limited and H.W. Wood Limited, two U.K.-based reinsurance brokers, have agreed to resolve investigations by the Justice Department into violations of the FCPA arising from Tysers’ and H.W. Wood’s participation in a corrupt scheme to pay bribes…

US DoS designates Kosovan public official, Nexhat Krasniqi, for significant corruption

As a public official responsible for oversight of procurement contracts, Krasniqi abused his public position by accepting bribes in exchange for awarding a contract permitting the construction of an industrial park in the Drenas municipality by the operating company Eltoni.

United States seeks to forfeit more than $72 million involved in bribery and money scheme

The US filed a civil forfeiture complaint seeking to forfeit more than $72 million involved in a bribery and money laundering scheme centered around Ecuador’s public police pension fund (ISSPOL). As alleged in the complaint, from 2014 through 2020, more than $2.6 million…

US DoJ orders Albemarle to pay over $218M to resolve Foreign Corrupt Practices Act investigation

Between 2009 and 2017, Albemarle, through its third-party sales agents and subsidiary employees, conspired to pay bribes to government officials to obtain and retain chemical catalyst business with state-owned oil refineries in Vietnam, Indonesia, and India. Albemarle obtained profits of approximately $98.5 million as a result of the scheme.

SEC charges Clear Channel Outdoor with FCPA violations relating to China Subsidiary

The order finds that, from at least 2012 through 2017, Clear Media bribed Chinese government officials to obtain contracts required to sell advertising services to public and private sector clients for display on public bus shelters and other outdoor displays.

SEC charges Exelon, its subsidiary Commonwealth Edison, and subsidiary’s Former CEO Anne Pramaggiore with fraud in connection with political corruption scheme

Exelon to pay $46 million penalty to settle; SEC files suit against former CEO in District Court

US DoS releases implementation plan for for the U.S. Strategy on Countering Corruption

This Implementation Plan articulates activities the Department is
undertaking to achieve the five pillars of the Strategy:

1. Modernizing, Coordinating, and Resourcing Efforts to Fight Corruption
2. Curbing Illicit Finance
3. Holding Corrupt Actors Accountable
4. Preserving and Strengthening the Multilateral Anti-Corruption
Architecture
5. Improving Diplomatic Engagement and Leveraging Foreign Assistance
Resources to Advance Policy Goals

US DoJ issues first FCPA Opinion Procedure Release of 2023

Guidance provided on the payment of travel and other expenses for foreign government officials.