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North America Prepared By August 2017 Keeping ahead of global anti-corruption trends is critical in today’s business markets. The Dorsey Anti-Corruption Digest, which puts global trends at your fingertips, puts you ahead. The deep experience of the Dorsey Anti-Corruption team, drawn from the DOJ, the SEC and years in private practice, will keep you ahead. NORTH AMERICA PREPARED BY: THE UNITED STATES Tom Gorman DOJ Ends Probe into Net1 Partner The Department of Justice (DOJ) ended its probe of Net1 UEPS Technologies, according Zach Davison to SEC filings from the South African-based Associate payment processing company. The company received a declination from the Securities and Exchange Commission (SEC) in 2015 Kim Frumkin regarding the same matter, but the DOJ Associate investigation continued until now. The probe started after an African Barclays Chad Richards unit lost a bid and approached the DOJ about possible corruption related to the tender. In Associate December 2012, Net1 disclosed that the SEC, DOJ, and Federal Bureau of Investigation (FBI) were investigating payments to South African government officials to win a contract with that country’s Social Security Agency. The investigation, considered unusual when it was announced as it related to a local issue, involved a South African company, allegedly 1 of 17 bribing South African government officials to undertaken by the Polish Central Anti- win a South African contract. The probe was Corruption Bureau. That probe related to initiated after a South African court agreed the alleged illegal activity by a former IBM Poland tender process was irregular and corrupt, but employee regarding sales to the Polish refused to set aside the tender. government. When the DOJ joined the investigation in 2013, it expanded the probe to Colombian Anti-Corruption Chief conduct in Argentina, Bangladesh, and Arrested For Bribery after Giving Ukraine. Corruption Speech FBI Nominee Wray Tells Senate Luis Gustavo Moreno Rivera, the head of the Trump Organization FCPA Probe national anti-corruption unit in the Colombian Not Off Limits attorney general’s office, was indicted in the U.S. after Drug Enforcement Agency (DEA) The Senate Judiciary Committee grilled agents in Miami recorded him agreeing to take President Trump’s FBI Director nominee, bribes. U.S. v. Moreno Rivera et al., Case No. Christopher Wray, on his perception of the 1:17-mj-02885 (C.D. Fla.) (Filed June 27, Bureau’s enforcement duties. Specifically, 2017). Ironically, Mr. Moreno Rivera was in Sen. Dianne Feinstein (D. Cal.), who serves Miami to give an anti-corruption presentation as the committee’s ranking member, asked to Internal Revenue Service (IRS) what Mr. Wray would do if the Trump investigators. Mr. Moreno Rivera was charged Organization or family may have violated the with one count of conspiracy to launder money FCPA. Sen. Feinstein referenced a New in order to promote foreign bribery. Yorker magazine article that had raised corruption questions about the Trump According to prosecutors, Mr. Moreno Rivera organization’s ventures in Azerbaijan. Mr. agreed to take $132,000 in cash to discredit a Wray responded that he would follow the facts witness in a case before the IRS. The IRS and law, wherever they might lead: “If the FBI case involved an investigation into a is provided credible evidence suggesting that Colombian governor, Alejandro Lyons Muskus a crime had been committed, I would expect of Córdoba. The governor reportedly agreed to the FBI to investigate appropriately and, if wear a wire in a meeting with Mr. Moreno merited, to support the prosecution of such Rivera in Miami. U.S. DEA agents found some crimes.” Mr. Wray’s FBI nomination passed of the bribe money on Mr. Moreno Rivera and the Senate Judiciary Committee in a 20-0 vote his wife when they were traveling back to on July 20. His nomination is expected to go Colombia, according to the indictment. before the Senate prior to the August recess. Mr. Moreno Rivera was arrested in Colombia UAE Ambassador to the U.S. after Interpol issued a red notice for him. He is being held at La Picota prison in Bogota, Tied to 1MDB Fund Fraud pending his extradition to the U.S. United Arab Emirates (UAE) ambassador to the U.S., Yousef Al Otaiba, received $66 FCPA Probe of IBM Closed million from offshore companies tied to the The SEC and DOJ have closed their four year alleged $4.5 billion fraud involving the investigation into IBM’s transactions in Malaysian state investment fund, the 1MDB Argentina, Bangladesh, Poland, and Ukraine, fund, according to the Wall Street Journal, according to an SEC filing by IBM. The U.S. which cited court and investigative documents. investigation commenced in early 2012 when Leaked emails show meetings between an IBM notified the SEC of an investigation associate of Mr. Otaiba and Jho Low, the Malaysian financier who is at the center of the 2 of 17 alleged 1MDB fund fraud. Mr. Low has been CDM had been working on a consulting connected to a number of illicit purchases, contract for the Da Nang Priority Infrastructure according to U.S. prosecutors. Mr. Otaiba and Investment Project in Vietnam, which was the UAE embassy in Washington declined to financed by the World Bank. While working on comment on the purpose of the transfers. the project, CDM failed to disclose a sub- consulting agreement with a local Vietnamese Former DOJ Compliance company and failed to seek contractually- Counsel Takes to LinkedIn Again required written approval of the agreement, according to the World Bank. Former DOJ compliance counsel Hui Chen The sanction started on June 29 and will run stated in a June 25 LinkedIn post that she until December 28, 2018. CDM’s resolution could no longer work for the Trump agreement also requires the engineering administration. Ms. Chen said she felt it company to adopt a corporate compliance hypocritical to demand compliance from program that is “consistent with the World companies while President Trump stood Bank Group Integrity Compliance Guidelines, accused of conduct she “would not tolerate and fully cooperate with the Bank in advancing seeing in a company.” She also felt limited by its anticorruption work.” DOJ criminal division leadership after they prohibited her from speaking publicly. “This inability to engage was particularly frustrating Peru Dismisses Odebrecht after the release of the Evaluations of Special Counsel amid Corruption Corporate Compliance document, as I Scandal watched almost everyone except me being able to talk about (and often misinterpreting) The Peruvian government has dismissed the my work,” Ms. Chen wrote. special counsel in charge of investigating Odebrecht’s corruption. The change comes Ms. Chen notified the DOJ in mid-May that she amid increasing regional fallout stemming would not renew her contract. She officially from the massive bribery scandal previously ended her work with the DOJ on June 21. Prior reported in the Digest. to leaving government, Ms. Chen had become an outspoken critic of the Trump Justice Minister Marisol Perez said she administration, taking to Twitter to criticize dismissed special attorney Katherine U.S. Attorney General Jeff Sessions’ refusal to Ampuero after she blocked Odebrecht’s sale answer certain questions in a recent Senate of its irrigation company. Odebrecht has Intelligence Committee hearing. sought to offload assets in the wake of over $2.5 billion in global criminal penalties after CDM Smith Sanctioned by World agreeing to settle bribery offenses late last Bank after FCPA Settlement year. The decision put thousands of jobs at risk and deprived the Peruvian government of Engineering giant CDM Smith, which settled revenues it could have seized as payment for Foreign Corrupt Practices Act (FCPA) charges reparations, according to Justice Minister last month as reported in the Digest, was Perez. Some Peruvian lawmakers, as well as “conditionally non-barred” for one and a half Ms. Ampuero, criticized the decision. years by the World Bank for failing to disclose Odebretch’s proposed sale will remain a subcontract on a project in Vietnam. A blocked pending an appeals court’s decision “conditional non-debarment” means that CDM on whether to allow the sale to move forward. can participate in World Bank-financed projects, but only if it meets the conditions of The Odebrecht corruption scandal has continued to reverberate throughout the its negotiated resolution agreement. region. Three fund managers identified the 3 of 17 scandal as risk factors to Latin American Nigerian minister for petroleum resources, by infrastructure investment in recent SEC filings. buying her multimillion dollar properties in The filings noted that the Odebrecht scandal London as well as expensive furnishings and has produced “widespread fallout” in the artwork, according to the complaint. In return, region, with “governments across Latin Aluko and Omokore obtained lucrative America” announcing investigations, fines contracts to finance oil production and and, in certain countries, outright bans on the exploration. This gave them the opportunity to construction firm’s operations. The filings receive a portion of the oil and gas that was concluded that there “may be wider produced. As a result, the Nigerian implications for the Latin American banking businessmen earned more than $1.5 billion sector, as banks exposed to entities affiliated from the sale of crude oil, despite failing to with Odebrecht could suffer loan losses and meet certain obligations in the contracts. The will likely adopt a more cautious stance when duo then used shell companies and other lending to infrastructure concessionaires in the transactions to launder some of the proceeds future.” through the U.S. The government of Peru echoed the warnings The former oil minister also faces a slew of by the fund managers in SEC filings for its international corruption charges in Nigeria bonds: “Peruvian authorities are currently relating to her involvement in siphoning billions conducting several high-profile corruption of dollars from oil deals and state coffers.
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