This post highlights nine FCPA enforcement actions concerning conduct (in whole or in part) in Egypt.
The enforcement action concerned conduct in Egypt and alleged that from “2016 until early 2020, certain of Corsa’s employees and agents engaged in a scheme to bribe Egyptian government officials in order to obtain and retain lucrative contracts to supply coal to Al Nasr Company for Coke and Chemicals (“Al Nasr”), an Egyptian state-owned and -controlled coke company. To effectuate the scheme, Corsa paid approximately $4.8 million to an Egypt-based third-party intermediary that Corsa’s employees knew would be used, at least in part, to pay bribes to Egyptian government officials, including the Chairman of Al Nasr. In exchange for the bribe payments, Corsa secured approximately $143 million in coal contracts from Al Nasr and earned approximately $32.7 million in profits.” Individual enforcement actions were also based on the same core conduct.
This post highlights seven FCPA enforcement actions concerning conduct (in whole or in part) in Egypt.
The enforcement action against Cyrus Ahsani and Saman Ahsani (the former CEO and Chief Operations Officer of Monaco-based Unaoil) concerned conduct in Iraq, Kazakhstan, Libya, Algeria, Iran, Azerbaijan, Angola, Syria, the Democratic Republic of the Congo, and elsewhere.
As to Libya, the enforcement action concerned various schemes involving foreign government officials including at a state-owned oil and gas company to obtain and retain business for Unaoil and its client companies. The information refers to Libya Official 1, but states that S. Ahsani and others “understood that Libya Official 1 was not an appointed Libyan government official at the time they promised to pay Libya Official 1” but that “Libya Official 1 could exert influence over senior Libyan government officials, including one official who was a close relative of the then head of the Libyan government, and that this senior Libya official’s support or lack of support could determine whether” a company won an award for a project. Based on the same core conduct, Steven Hunter (a former business development manager at Unaoil) resolved an enforcement action.
This post highlights approximately 20 FCPA enforcement actions concerning conduct (in whole or in part) in Russia.
The enforcement action concerned conduct in Russia.
The allegations were: “Between May 26, 2015 and May 15, 2020, the Company paid approximately $8.9 million to consultants in Russia in support of the Company’s operations and its efforts to have poker legalized in that country.”
Checking in on the back and forth between the DOJ and Judge Nicholas Garaufis (E.D.N.Y.).
In 2024, the DOJ criminally charged various individuals in connection with an alleged Indian bribery scheme. (See here for the prior post).
In mid-August, Judge Nicholas Garaufis (E.D.N.Y.) – after much back and forth with the DOJ – granted the DOJ’s motion to dismiss various non-FCPA fraud charges against certain defendants.
However, Judge Garaufis denied the motion to dismiss FCPA and obstruction charges against certain other defendants (see here for the prior post) while noting “the court’s conclusion does not mean that additional evidence to support […] proffered reason to dismiss does not exist. It means only that the factual support that McCotter has provided is not sufficient.”
As highlighted in this recent post, Javier Aguilar (a former employee of Vitol Inc.) was sentenced to four years in prison after being found guilty at trial for paying bribes to Ecuadorian officials as well as related offenses and after pleading guilty to a bribery scheme in Mexico.
Aguilar was also ordered to approximately $7.13 million in criminal forfeiture and a $100,000 fine.
In sentencing Aguilar, U.S. District Judge Eric Vitaliano (E.D. N.Y) considered the sentencing briefs of Aguilar (who requested a non-custodial sentence) and the DOJ (who requested a 12 year sentence).