FCPA Professor LLC

FCPA Professor LLC Blogs

Blog Authors

Latest from FCPA Professor LLC

Yesterday, new Attorney General Pam Bondi issued this memo titled “Total Elimination of Cartels and Transnational Criminal Organizations.”
The memo begins as follows.
“On January 20, 2025, President Trump directed the federal government to revise existing national security and counter-narcotics strategies to pursue total elimination of Cartels and Transnational Criminal Organizations (TCOs). This policy requires

From time to time, an issue appears in the news which demonstrates how some conflate the Foreign Corrupt Practices Act (the actual statute) and how the FCPA is enforced by the DOJ / SEC.
For instance, as highlighted here, Louis Sola (the newly appointed head of the Federal Maritime Commission) recently commented how China

In Fall 2024, Glenn Oztemel (previously employed by Arcadia Fuels Ltd. and Freepoint Commodities LLC) was found guilty at trial of FCPA and related offenses in connection with a Brazil bribery scheme.
As stated in the DOJ release: “According to court documents and evidence presented at trial, Oztemel […] paid bribes to officials of Petróleo Brasileiro

Remember when a high-ranking Department of Justice official declared in 2017 that it was the intent of the DOJ “for our FCPA investigations to be measured in months, not years.” (See here for the prior post).

The statement was laughable when made and remains laughable approximately eight years later because since the statement was made

In 2018, the DOJ unsealed criminal charges against Raul Gorrin Belisario, a prominent Venezuelan businessman and described by the DOJ as a citizen and national of Venezuela who at various time periods relevant to the charges was a resident of the U.S. with a residence in Florida. (See here).
According to the criminal indictment,

The credibility and persuasive of some commentators was diminished during the first Trump administration as their seeming disdain for one person (whether warranted or not is besides the point) impacted much of their commentary.
Some sit in front of a computer screen from their home offices with action figures in the background and give themselves

If the Foreign Corrupt Practices Act is an area of your practice or interest, this post may make you feel like a kid in a candy store.
FCPA Professor has been the place to visit this month for in-depth 2024 FCPA enforcement statistics as well as comparisons to historical statistics. If you missed the daily