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The V&E Report
Insights in Government Enforcement and Investigations

SEC Enforcement Report Signals Increased Enforcement, Lingering Limitations from Kokesh

Last week on November 6, 2019, the SEC Enforcement Division released its annual report on the Commission’s enforcement activities for the fiscal year. This article discusses prominent takeaways from the report, and what these and other findings mean for companies under the SEC’s jurisdiction.

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DOJ’s FCPA Reach Over Foreign “Agents”

The Criminal Information against two former executives of Unaoil, Inc. was unsealed on October 30, 2019, laying out the U.S. government’s case against them for facilitating bribes on behalf of companies in foreign countries in exchange for oil and gas contracts.1 Former CEO Cyrus Ahsani and former COO Saman Ahsani, both citizens of the United Kingdom, pled guilty to conspiracy to violate the Foreign Corrupt Practices Act (“FCPA”), 15 U.S.C. § 78dd-1 et seq.2

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U.K.’s SFO Recognizes Expectation that Compliance Functions Will be Insulated from Routine Cost Cutting Pressures

Sarah Lawson, the General Counsel of the U.K.’s Serious Fraud Office (“SFO”), recently emphasized that corporate compliance functions must be well resourced and that the SFO expects such programs should be insulated from routine cost-cutting pressures. This expectation parallels the U.S. Department of Justice (“DOJ”)’s long-standing focus on corporate compliance programs and its own recent focus on ensuring that compliance functions are provided with sufficient resources.

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Commodities in the Crosshairs: CFTC Joins DOJ and the SEC to Target Commodity Traders for Corrupt Practices Abroad

The U.S. Commodity Futures Trading Commission (“CFTC”) is entering the fight against foreign bribery and corruption. That is the clear message from recent announcements as the CFTC has made clear that it wants to join the U.S. Department of Justice (“DOJ”), the Securities and Exchange Commission (“SEC”) and foreign authorities by targeting commodity firms that commit corrupt practices outside the U.S.

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  • 03
  • September
  • 2019

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For Whom the Statute Tolls: Challenges to FCPA Indictment May Expose Government Vulnerabilities in International Cases

As companies grow and expand their international footprint, their operations are scrutinized with increasing frequency by federal prosecutors. However, recent pre-trial litigation in a FCPA case suggests that one important government tool may be vulnerable to challenge by sophisticated defense counsel, which could stifle the government’s ability to build and bring a criminal case beyond the normal five-year limitations period, provided the defense can show that the government’s mutual legal assistance request to another country was pretextual in nature.

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  • 23
  • July
  • 2019

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DOJ Signals FCPA Policy Shift Focusing on M&A Transactions, Creating New Incentives and Heightened Risks for Companies on Both Sides of Deals

A recent expansion by the Department of Justice (“DOJ” or the “Department”) to its FCPA Corporate Enforcement Policy (“CEP”) has gone largely unnoticed, but the shift in policy now provides new incentives for companies to self-report misconduct that is discovered after a merger or acquisition, while also raising the specter of increased exposure for companies and executives who sell assets tainted by corruption. 

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