Resolutions involving the Foreign Corrupt Practices Act have continued at a “slow” pace in 2022, with only one announced FCPA-related corporate enforcement action during the first quarter of 2022, Miller & Chevalier said in its FCPA Spring Review released May 25. DOJ announced just two bribery-related guilty pleas in the first quarter and two FCPA-related indictments, the firm said. “This pace is consistent with the slower pace of such cases in 2021 and is well behind the pace that marked recent higher volume years such as from 2017 to 2019.”
Luis Enrique Martinelli Linares and Ricardo Enrique Martinelli Linares, brothers who are both dual citizens of Panama and Italy, were sentenced to 36 months in prison each for laundering $28 million in a bribery and money laundering scheme with Brazilian construction conglomerate Oderbrecht S.A., DOJ announced. The U.S. District Court for the Eastern District of New York also ordered the brothers to forfeit more than $18.8 million and pay a $250,000 fine along with serving two years of supervised release.
Elizabeth Boison, previously with DOJ's Bank Integrity Unit and National Cryptocurrency Enforcement Team, joined Hogan Lovells as a partner in the Global Regulatory and Intellectual Property, Media and Technology practice group, the firm announced. During her time in government, Boison also worked with the Treasury Department's Financial Crimes Enforcement Network, where she helped craft guidance on the regulatory enforcement of financial crimes, the firm said. At DOJ, Boison focused on sanctions, asset forfeiture, the Foreign Corrupt Practices Act and other fraud-involved proceedings.
Grace Hill, former assistant U.S. attorney for the Eastern District of Virginia, in the Financial Crimes and Public Corruption Unit, has joined Wilkinson Stekloff as a partner, the firm announced. At EDVA, Hill prosecuted an array of white collar crime cases involving the Foreign Corrupt Practices Act, investment fraud, bribery and public corruption, the firm said.
International waste management company Stericycle agreed to pay over $84 million to settle investigations by the U.S. and Brazil into Foreign Corrupt Practices Act violations relating to bribes to Mexican, Argentinian and Brazilian officials, DOJ announced April 20. Stericycle entered into a three-year deferred prosecution agreement over a criminal case charging the company with two counts of conspiracy to violate the FCPA's anti-bribery provision and books and records provision.
Roger Ng, former managing director of The Goldman Sachs Group, was convicted by a federal jury in the Eastern District of New York for violating the Foreign Corrupt Practices Act in a scheme with Malaysia's state-owned investment and development fund, 1Malaysia Development Berhad, DOJ announced. Ng was found guilty of conspiring to bribe a dozen foreign officials in Malaysia and the United Arab Emirates to obtain business for Goldman Sachs from 1MDB.
Charles Hunter Hobson, a former coal company executive, was arrested for allegedly violating the Foreign Corrupt Practices Act in a scheme to bribe Egyptian government officials over contracts with an Egyptian state-owned company, Al Nasr for Coke and Chemicals, DOJ said. Hobson, of Knoxville, Tennessee, is also charged with laundering funds and receiving kickbacks. He faces one count of conspiracy to violate the FCPA, two counts of violating the FCPA, one count of conspiracy to launder money, two counts of money laundering and one count of conspiracy to commit wire fraud.
Michelle Schulz, a former member of the President's Export Council Subcommittee on Export Administration, rejoined the Braumiller Law Group as of counsel, the firm announced in an email. Schulz was one of the founders of the Braumiller Law Group, helping start the firm in 2003 when it was known as Braumiller Schulz. Schulz also served for a decade as a senior adviser to the Office of the U.S. Trade Representative's Industry Trade Advisory Committee for Aerospace. Her practice deals with export controls, including matters under the International Traffic in Arms Regulations and Export Administration Regulations, along with Foreign Corrupt Practices Act cases and Committee on Foreign Investment in the U.S. regulations, the firm said.
Daniel D'Andrea Golindano and Luis Javier Sanchez Rangel, two former senior Venezuelan prosecutors, were charged with money laundering for accepting over $1 million in bribes in a Foreign Corrupt Practices Act matter, DOJ said March 8. Each is charged with one count of conspiracy to commit money laundering and two counts of engaging in monetary transactions in criminally derived property. D'Andrea and Sanchez face up to 20 years in prison for the conspiracy to commit money laundering charge and up to 10 years in prison for each count of engaging in transactions in criminally derived property.
Daniel Pickard, previously an international trade partner at Wiley, joined Buchanan Ingersoll as the chair of its International Trade and National Security practice group, the firm announced. Pickard deals with matters concerning trade remedy investigations, including antidumping and countervailing duty and safeguard cases; U.S. economic sanctions; anti-bribery cases; export controls; the Foreign Corrupt Practices Act; and national security, the firm said. His national security practice deals with export controls and anti-boycott proceedings.