As detailed below, in the past approximate five years, there have been several FCPA enforcement actions against companies and individuals involved in the insurance sector in Ecuador.
Tysers Insurance Brokers Limited and H.W. Wood Limited (2023)
As highlighted in this prior post, the DOJ alleged that “Tysers and H.W. Wood were engaged in a…

Dan Seltzer (Managing Director; Senior Director of Anticorruption and Government Compliance at Accenture) recently published this post titled “FCPA Developments.”
This post poses a number of questions to Seltzer in an effort to understand some of his assertions and commentary.
Can you provide the number of “FCPA-like” enforcement actions the U.K., France, and Switzerland have…

Fifteen years ago, there was a “pause” in FCPA enforcement.
No, not pursuant to an Executive Order, but as a practical matter.
According to the Department of Justice, BAE served as the “prime contractor to the U.K. government following the conclusion of a Formal Understanding between the U.K. and the Kingdom of Saudi Arabia (“KSA”)” in…

In November 2024, Digicel disclosed Foreign Corrupt Practices Act scrutiny (see here for the prior post).
Specifically, the company stated:
“We voluntarily disclosed to the US Department of Justice information related to possible violations of the US Foreign Corrupt Practices Act. We are cooperating fully with the DOJ and will continue to do so.”
As…

Some Foreign Corrupt Practices Act enforcement actions have focused on “foreign officials” receiving tickets to major sporting events such as the Olympics or World Cup.
In the BHP Billiton enforcement action, the U.S. government stated: “BHP Billiton footed the bill for foreign government officials to attend the Olympics while they were in a position…

Last week when the DOJ dismissed its long-standing FCPA enforcement action against former Cognizant Executives Gordon Coburn and Steven Schwartz, I told anyone who would listen that it was wrong to view the development exclusively through the lens of the Executive Order given that the matter had several legal and factual deficiencies.
Since then,…

As highlighted in this prior post, in August 2024 the DOJ announced that a “federal grand jury in the Southern District of Florida returned an indictment … charging three executives of an election voting machine and service provider company and a former Chairman of the Commission on Elections (COMELEC) of the Republic of the Philippines…