Anticorruption Developments

  • Keppel Offshore Reaches Deal with DOJ and Guilty Plea by Counsel Unsealed
  • Guilty Plea by Former Embraer Executive Regarding Aramco Bribes
  • Odebrecht Corruption Reaches High-Level Officials in Peru, Colombia and Ecuador
  • Former DOJ Fraud Section Official Outlines FCPA's Successes and Failures 40 Years On
  • U.S. and UK Regulators Indicate They are Moving Towards Regulating Bitcoin as Part of AntiCorruption Laws
  • French Power Infrastructure Firm Sediver SAS Debarred by The World Bank for Two Years
  • French Digital Security Company Oberthur Technologies Debarred by The World Bank for Two and a Half Years
  • Additional Charges by UK Serious Fraud Office in Unaoil Investigation
  • Anticorruption Spotlight: SEC Issues WhistleBlower Determination

Export Control and Sanctions Enforcement

  • OFAC Issues a Finding of Violation to International Ship Registry for a Violation of Iran-Related Sanctions
  • Dental Supply Company Agrees to Pay $1,220,400 to Settle Alleged Civil Liability for Iran-Related Sanctions Violations

Export Control and Sanctions Developments

  • Trump Administration Issues Executive Order on Human Rights Abuse and Corruption; OFAC Issues Regulations Implementing the Magnitsky Act and Related FAQs
  • OFAC Publishes 2016 Terrorist Assets Report
  • Treasury, State and Commerce Implement Regulations Pursuant to the Trump Administration's Cuba Policy

Global Investigations Resources

  • Client Alert: Treasury, State and Commerce Implement Regulations Pursuant to the Trump Administration's Cuba Policy
  • Client Alert: DOJ Deputy Attorney General Rod Rosenstein Announces FCPA Corporate Enforcement Policy
  • Writing and Speaking Engagements

Keppel Offshore Reaches Deal with DOJ and Guilty Plea by Counsel Unsealed

On December 22, 2017, Keppel Offshore & Marine Ltd. (KOM), a Singapore-based company that operates shipyards and repairs and upgrades shipping vessels, and its wholly owned subsidiary, Keppel Offshore & Marine USA Inc. (KOM USA), agreed to pay more than $422 million to resolve the Department of Justice's (DOJ) investigation of alleged violations of the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA) as well as parallel investigations by Brazilian and Singaporean enforcement agencies. KOM entered into a non-prosecution agreement with the DOJ while KOM USA and a former senior member of KOM's legal department pleaded guilty in connection with the resolution. Specifically, the DOJ alleges, beginning in at least 2001 and continuing until at least 2014, KOM paid approximately $55 million in bribes to officials at the Brazilian state-owned oil company Petrobras and to the then-governing political party in Brazil. The DOJ further alleges that KOM concealed the payments by paying outsized commissions to an intermediary, under the guise of legitimate consulting agreements, which the in-house attorney is alleged to have drafted.

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