Hughes Hubbard Releases 2022 FCPA Alert

December 13th, 2021 Hughes Hubbard & Reed LLP Leave a comment

Hughes Hubbard & Reed today released its 2022 FCPA Alert, a comprehensive review of the global cases, trends and enforcement actions that impacted anti-corruption law, multinational corporations and individuals to date this calendar year. For the 13th consecutive year, the highly respected and anticipated annual FCPA Alert highlights the most important trends and lessons for in-house counsel and compliance professionals.

The FCPA Alert’s contributors, led by Laura N. Perkins and Kevin T. Abikoff, co-chairs of Hughes Hubbard’s Anti-Corruption & Internal Investigations practice group, expect enforcement to surge – due in part to the Biden Administration’s recent memorandum on combatting corruption. Their analysis of recent enforcement actions suggests that going forward:

-The Department of Justice and Securities and Exchange Commission will be cooperating with an expansive number of domestic agencies and divisions to conduct complex bribery investigations, as well as a growing number of non-US enforcement agencies.

-Companies that have resolved FCPA matters through NPAs, DPAs or plea agreements should expect increased scrutiny and attention to compliance with ongoing obligations under such agreements.

-While commodities traders, in particular, can expect greater scrutiny, enforcement will continue in a diverse array of traditional and non-traditional industries and in high-risk jurisdictions, with special emphasis on the independence and authority of corporate compliance functions and complete and timely cooperation with enforcement agencies.

The 153-page Alert provides detailed descriptions of key matters from 2020 and 2021 that support these and other key takeaways.

“As enforcement leadership has evolved this year under a new administration in Washington, we’ve witnessed renewed vigor in the investigation and prosecution of bribery and corruption in the United States and abroad,” said Abikoff. “As the regulators continue to leverage greater resources and reach into new industries, it is vital that companies and compliance departments remain vigilant in enforcing their compliance programs.”

The Alert also contains a deep dive into anti-bribery enforcement and developments in France, Brazil, United Kingdom, China, Mexico, and by multilateral development banks. For the first time, the Alert includes a discussion of the rapidly developing intersection between transnational corruption issues and international arbitration. This discussion highlights examples of how tribunals and courts have treated corruption claims in arbitration in recent years and provides insight into key questions raised by bringing claims in arbitration proceedings, regarding the burden of proof, the identification and treatment of red flags, and the impact of government investigations.

“An effective compliance program is more than words on paper,” said Perkins, a former supervisor in the DOJ’s FCPA Unit. “Prosecutors will pursue companies that have established but ineffective programs in place. It’s critical that companies adequately staff and empower their compliance departments, conduct due diligence, address red flags and allegations, and follow-though on their obligations. Every year, our analysis cites example after example of the downsides to a lack of vigilance. Especially given the expected surge in enforcement now is not the time to take your eye off the ball.”

The complete report is available for download here.

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About the Anti-Corruption & Investigations Practice Group

Hughes Hubbard’s Anti-Corruption & Internal Investigations Practice Group handles the full range of matters across the anti-corruption and compliance spectrum. It has conducted investigations in more than 90 countries involving the FCPA and other anti-corruption laws, resolved investigations and won landmark decisions for clients before U.S. and international authorities, and has served as compliance monitors approved by the Department of Justice, the Securities and Exchange Commission, the U.K. Serious Fraud Office, the Department of the Treasury’s Office of Foreign Assets Control and the United Nations.

Lawyers in the group include former senior government enforcement officials, corporate compliance counsel, foreign-trained attorneys and certified public accountants located in the United States and France. The group has many longstanding relationships with leading local firms in countries across the world with which it works closely on cross-border matters, including a strategic cooperation agreement with leading Brazilian anti-corruption firm Saud Advogados.

About Hughes Hubbard

Hughes Hubbard & Reed is a New York City-based international law firm that offers clients results-focused legal services and a collaborative approach across a broad range of practices. Hughes Hubbard was founded in 1888 by the renowned jurist and statesman Charles Evans Hughes. The firm is a leader in promoting diversity and is recognized for its pro bono achievements. For more information, visit hugheshubbard.com.

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FCPA Enforcement Under the Biden Administration: Three Areas to Watch

March 30th, 2021 Michael DeBernardis, Benjamin Britz, and Debbie Placid Leave a comment

Foreign Corrupt Practices Act (“FCPA”) enforcement under the Trump administration was both remarkable and perhaps unexpected. As a candidate and private citizen, former President Trump had been openly critical of the FCPA, which he had referred to as a “horrible law.” This led many to wonder whether the long run of FCPA enforcement was coming to an end. Instead, the DOJ and SEC obtained record FCPA penalties from 2017 to 2020. In 2020 alone, the DOJ and SEC secured 18 corporate FCPA resolutions, including the two largest penalties ever issued for FCPA violations (against Airbus and Goldman Sachs). Given the results in 2020, it may seem alarmist to suggest that we will see even more FCPA enforcement during the Biden administration. But, that is exactly what we expect.

First, the record-breaking numbers during the Trump administration only tell half of the story. The largest and most noteworthy penalties related to investigations that began years before. FCPA enforcement did not cease during the Trump administration as many speculated, but fewer FCPA-related investigations were initiated year over year from 2017 to 2020. We expect a reversal of that trend under the Biden administration.

Second, Biden and his team appear poised to tackle FCPA violations with renewed vigor. The Biden administration has framed the fight against corruption as a central part of its foreign policy strategy. During the campaign, candidate Biden vowed to “issue a presidential policy directive that establishes combating corruption as a core national security interest and demographic responsibility.”^[1]

President Biden’s appointees, ranging from National Security Advisor Jake Sullivan to Attorney General Merrick Garland and SEC Chairman Gary Gensler, have confirmed a commitment to focus on combating corruption around the world. This focus, bolstered by the hiring of seasoned lawyers to fill key roles within the DOJ’s and SEC’s foreign bribery units, as well as new enforcement tools authorized by the U.S. Congress, all but ensures that the FCPA will be a key enforcement priority for the Biden administration.

Finally, the freshly equipped and motivated DOJ and SEC should have no shortage of opportunities to prove their mettle. Since early 2020, companies have been dealing with financial stress caused by the pandemic, while compliance departments have been dealing with layoffs and limitations associated with remote monitoring. History shows that financial stress creates incentives for fraud as companies and employees face pressure to meet financial targets. In other words, the DOJ and SEC, eager to demonstrate a commitment to combating corruption, maybe meeting a wave of potential corruption cases.

There are three areas we suggest watching as the Biden administration’s anti-corruption approach takes shape:

Impact of new tools authorized by Congress – Biden’s FCPA enforcement agenda may be bolstered by new enforcement tools recently authorized by Congress. In particular, in January 2021, Congress enacted the Corporate Transparency Act (“CTA”) as part of the National Defense Authorization Act. The CTA requires companies that are registered in the United States to report their ultimate beneficial ownership to the Treasury Department’s Financial Crime Enforcement Network. The information, though not public, will be available to law enforcement and banks.

The CTA is designed to prevent individuals from hiding transactions behind shell companies to circumvent anti-corruption, anti-money laundering, and other laws. The impact of the CTA on FCPA investigations remains to be seen. Given the international nature of the activities involved, wrongdoers have historically utilized shell companies outside of the U.S., often in jurisdictions that allow for more opaque ownership arrangements. The CTA will have no effect on these companies. However, the CTA could limit corrupt funds from finding safety in the U.S. market and may make it easier for investigators to “follow the money” when U.S. companies are involved.

International Coordination in FCPA Investigations – The largest and most significant FCPA resolutions often demand coordination between the U.S. DOJ and SEC and foreign regulators. In 2020, the DOJ and SEC coordinated with foreign regulators in the resolution of the four largest enforcement actions: those with Goldman Sachs, Airbus, J&F Investmentos, and Vitol. The extent to which the Trump administration’s combativeness toward traditional allies may have affected these resolutions or active investigations is hard to quantify. Nevertheless, given the Biden administration’s pointed emphasis on working closely with allies on most of its foreign policy goals, we expect that coordination with foreign regulators in the FCPA context will only increase, with new partners brought into the fold.

This is a view apparently shared by Daniel Kahn, Acting Fraud Section Chief (DOJ), who indicated during a March 2021 International Bar Association webinar that he expected an increase in multi-jurisdiction investigations and resolutions, including with foreign authorities that U.S. enforcers have not previously coordinated with. In addition, improving relations and cooperation generally could lead to greater efficiency in the way that regulators share evidence and coordinate resolutions. This could potentially significantly reduce the time it takes to conclude these complex cross-border investigations.

Approach Toward Monitorships – In 2020, none of the 18 corporate FCPA resolutions involved the imposition of an independent compliance monitor. Whether this was a result of the changes made in 2018 to the DOJ’s guidance on corporate compliance monitors (in a document often referred to as the “Benczkowski Memo”) is unclear. However, it does appear that the leadership of the DOJ and SEC during the Trump administration took a more restrained approach toward the use of monitors. We expect that the DOJ and SEC under the Biden Administration will be more likely to rely on monitorships in connection with FCPA resolutions, consistent with the approach taken during the Obama administration.

With all signs pointing to an increased focus on anti-corruption enforcement, the question is less if than when. Both the decrease in new investigations under the Trump administration and the practical limits on investigations imposed by the pandemic will take time to reverse. But when the tide eventually comes in, we expect the waves will be large.

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Written by Michael DeBernardis, Benjamin Britz, and Debbie Placid at Hughes Hubbard & Reed.

[1] Joseph R. Biden, Jr., Why America Must Lead Again, Rescuing U.S. Foreign Policy after Trump, Foreign Affairs (Jan. 23, 2020).

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Uncovering the Biggest Myths for Business in Latin America

March 30th, 2021 Haylle Sok Leave a comment

Conducting international business is not what it used to be. In the post-pandemic era, resilient regions throughout the world are at an advantage now more than ever. Unfortunately, business climates are at the mercy of a media-painted reputation impacting future economic growth. Latin America is no stranger to this. Businesses and workers in Latin America have been misrepresented in the media, particularly when it comes to corporate corruption and compliance. In this exclusive Q&A, Global Trade Magazine learns about the biggest misconceptions of doing business in Latin America by Pedro Freyre, chair of Akerman International Practice.

What are some common misconceptions for conducting business in Latin America and how does this impact the region’s economic reputation?

Pedro: One of the biggest misconceptions is that Latin American businesses are not up to speed on the use of technology. These misconceptions – or what some could call biases, are that businesses in Latin America are unsophisticated and they lack understanding complex issues. This is absolutely incorrect.

Latin America is a resilient, tough business environment with a lot of ups and downs, but also very global in that it deals with various jurisdictions in its trade relationships. I have found Latin American clients to be sophisticated and understanding of issues and nuances. There are always legal cultural differences and part of our job is that we are the interpreters that bridge this gap.

Latin American business and businessmen have lived for many years in difficult and volatile environments, making them very adaptable. They are fast on their feet and work with different cultures, buyers, and sellers, and various interlocutors very well because that is what they had to do to survive and succeed. This is one of the competitive advantages found here because that’s what businesses had to do to survive in the past. Latin Americans are incredibly open to dealing with different nationalities, markets, and opportunities.

How does your firm support Latin American clients in combatting issues with noncompliance and corporate corruption?

Again, our job is to bridge that gap – the legal cultural gap of raising awareness. Now more than ever there is a new and evolving set of stricter global standards in compliance, anti-corruption, and anti-money laundering. The web of those types of regulations is extending and becoming highly integrated. So, you have the FCPA in the U.S and the other anti-money laundering provisions, the UK anti-bribery act, the Brazilian anti-bribery act, and the Mexican anti-bribery act. All of these work to add layers of regulatory compliance..

Another factor coming into play is that we help clients deal with non-governmental regulators that look for compliance. For example, financial institutions ramping up their compliance department to act as guard dogs for the government. So, when a Latin American client comes over to the U.S and wants to open a bank account, we help them understand that there is going to be due diligence on the part of the bank and that they’re going to have to provide a lot of information. That is where the added value comes into play by emphasizing that compliance in today’s world is far more pervasive and necessary for any business.

What role does technology play in combating this corruption?

Technology is just as integrated in the effort. I will give you an example. We recently had a wire come in from one of our clients in Latin America and OFAC flagged it and started doing more background checks to identify the source of the funds because the name of the remitter was similar to a company that was on the Specially Designated Nationals list. The software picked up the name, tasking us to explain the situation.

What are some of the benefits of collaborating with Latin American-based businesses?

Latin America has vast natural resources. For example, Brazil is a leading provider of all kinds of natural resources. Back in the forties, Argentina was a main provider of grains and beef to Europe. The region was a tremendously powerful provider of these things. Currently, the Chinese are making inroads over Latin America in their search for raw materials and agricultural products. It’s part of the natural wealth of Latin America. Latin American businesses are now becoming much more integrated, enabling cross-border business.

How has the pandemic exacerbated the negative reputation for Latin American companies? What can companies do to overcome this?

This is a challenge because part of what happens is what companies predict in terms of government action. If a business climate has a government with a clumsy response to the pandemic, then the assumption is everybody in that country is at risk. It is not working, and things are in disarray, creating the need for uprooting and taking business elsewhere. And again, we go back to the point of resiliency and adaptability. Latin American businesses have been there before, they come from an exceedingly difficult environment, stability has always been a challenge. So, even in the pandemic, these businesses have been able to adapt and move forward. Adding to the misconceptions list is if the government did not react well to the pandemic, then the businesses are not able to function. That is simply untrue.
It is important to remember that this is a business climate fraught with peril and difficulties but is also full of opportunity. As the saying goes, out of great problems come great opportunities.

I anticipate a reshuffling of assets and business orientation and interests soon. We are seeing more flow out of Latin America and more flow to Latin America. This year is going to be a year of takeoff, although I do think Latin America may lag behind the U.S. I’m also keeping my eye on Brazil, which is going through great difficulties. Brazil is a major powerhouse, however, and I am betting on it overcoming these difficult times.

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Pedro Freyre is the chair of Akerman’s International Practice, a full-service team advising multinational and global corporations on a wide range of cross-border M&A, joint ventures, capital markets transactions, syndicated and secured lending, project finance, debt restructuring, trade, compliance, as well as complex construction and other international disputes. He is an internationally recognized authority on the U.S. Embargo on Cuba and the evolving regulations enacted since the restoration of diplomatic relations between the United States and Cuba. In addition, Pedro represents clients engaged in inbound foreign investment in the U.S. and outbound U.S. investment in Latin America.

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The Human Factor of the Novel Coronavirus (COVID-19) and Corruption

April 5th, 2020 Frank Orlowski Leave a comment

With the explosive spread of Coronavirus (COVID-19) hospitals, healthcare providers and all citizens are finding a shortage of goods and services and employees are under increased pressure to preserve and excel in their current roles.

Unfortunately, in this time of crisis corruption is thriving and some aim to profit from others’ misfortune and push companies to the brink to maintain profits.

Around the world, countries are reporting shortages in both medicines and medical supplies due to COVID-19. All of these factors put additional strain on already fragile procurement processes and increases the risk that suppliers, knowing that government and individuals have little choice but to pay, demand higher prices.

In these challenging times having open and transparent contracting processes in place helps mitigate these risks. With nowhere to hide, corrupt actors are unable to practice price gouging and must charge governments and individuals reasonable prices.

The stockpiling of supplies such as masks, gloves, and hand sanitizers are also contributing to shortages in medical supplies. In attempts to profit from public panic, some traders have been inflating prices for ordinary consumers.

After pressure from the Department of Justice, Amazon has implemented an effort to remove tens of thousands of deals from merchants that it said attempted to price-gouge customers. The world’s largest online retailer has faced scrutiny over the health-related offers on its platform, and earlier this week, Italy launched a probe into surging prices around the internet for sanitizing gels and hygiene masks. At the same time, Italy battles the biggest outbreak in Europe.

There are lessons to be learned in health-sector Corruption elsewhere from prior epidemics such as Ebola and SARS where procurement and contracting wrongdoing led to deadly consequences. In prior epidemics, Corruption compromised containment efforts, when corrupt actors used petty bribes and other favors to avoid quarantines, roadblocks, and safe body collection procedures. Even ventilators and other medical oxygen-related equipment have been the subject of bribes and kickbacks, sometimes leading to the tragic deaths of patients. These examples demonstrate the worst case of what can happen without resilient anti-corruption policies.

In the first federal action against fraud involving the coronavirus outbreak, the DOJ obtained a temporary restraining order against a website selling a bogus vaccine.

The DOJ said Sunday, March 21^st, that operators of the website “coronavirusmedicalkit.com” were engaging in an alleged wire fraud scheme to profit from the confusion and fear surrounding COVID-19.

The website claimed to offer customers access to the World Health Organization (WHO) vaccine kits in exchange for a shipping charge of $4.95. There are currently no legitimate COVID-19 vaccines, and the WHO is not distributing any such vaccine.

Besides compliance issues with third party business practices with goods and services, companies are experiencing enormous business pressure. Many companies have salespeople who cannot travel due to precautions taken, canceled flights, or, worse, quarantines. They cannot visit customers or partners, leading to slower sales. Global supply chains are disrupted, with shortages of parts and products. Company events and conferences are being canceled, resulting in fewer opportunities to build relationships with customers and market products. Customer demand for company products may be falling, and companies may be declining to make revenue projections during this time of uncertainty about the spread and effects of the coronavirus.

These disruptions can increase the pressure on salespeople to meet their sales targets. Salespeople may feel additional pressure now, when sales may be sluggish, and again when business gets back to normal, and they want to make up for the time lost. That pressure can lead some people to make the wrong choices—to engage in bribery or other misconduct—to generate business. Besides, the heightened emphasis on business priorities due to the losses from the coronavirus can push anti-corruption compliance further down on the priority list.

If/when the DOJ and SEC discover bribery or Corruption, they assuredly will not be accepting a “coronavirus defense” from companies. Compliance officers should be aware of situations like the coronavirus that could raise corruption risks and try to guard against them. Compliance officers should refer explicitly to the disruption caused by the coronavirus and emphasize that the company is committed to complying with anti-corruption laws. The communications must be to the employees who need to see them, such as salespeople who interact with customers, or “gatekeeper” functions like finance who review financial transactions.

Most importantly, senior executives and the board, if appropriate, need to make sure that the business pressures resulting from the coronavirus do not overshadow the company’s commitment to compliance and that values and ethics are maintained.

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For more information or questions, please contact Frank Orlowski at frank@ationadvisory.com or +1917-821-2147 and please visit our website at www.ationadvisory.com

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The Corruption Index: How it Relates to FCPA

January 8th, 2020 Frank Orlowski Leave a comment

The Corruption Perceptions Index (CPI) is an index published annually by Transparency International since 1995, which ranks countries “by their perceived levels of corruption, as determined by “expert assessments” and opinion surveys.

The CPI currently ranks 176 countries “on a scale from 100 (very clean) to 0 (highly corrupt)”. Denmark and New Zealand are perceived as the least corrupt countries in the world, ranking consistently high among international financial transparency, while the most perceived corrupt country in the world is Somalia, ranking at 9–10 out of 100 since 2017.

The estimated cost of corruption from Transparency International is over One Trillion Dollars or 2% of GDP. This represents an amount larger than most of the world’s economies

The top 10 least corrupt countries in the latest publication are:

-New Zealand

-Denmark

-Finland

-Norway

-Switzerland

-Singapore

-Sweden

-Canada

-Netherlands

-United Kingdom

It should also be noted that the top five on the list have some of the smallest populations on the planet potentially skewing the results as the index is not weighted. Additional smaller countries like Syria, South Sudan and Somalia are at the bottom of the list (178-180). However, they are considered war tourn countries. Larger population countries like China is ranked 77, and India is 81

Emerging Markets like Brazil is ranked 96, and Russia is 135. It is estimated that one in four people in Asian and Eastern European Societies have paid what is classified as a bribe multiple times in a year. It has also been estimated that law enforcement officers and government officials were most likely to receive a bribe where young people (under the age of 25) were most likely to pay a bribe. However, bribing is not limited to Emerging Markets. It is estimated that 13% of European Public Works Projects include the cost of bribing. This includes major infrastructure projects such as airport and rail construction, roads and government hospital or administrative buildings

One could argue that there could be a direct correlation between the number of FCPA Violations and how high a country rank on the Corruption Perception Index (CPI). Upon analysis, there is no such association and therefore the reliance by Chief Compliance Officers on the CPI as published each year by Transparency International comes into question

Upon further investigation of the survey developers – Transparency International (TI) based in Berlin Germany, it becomes clearer why the survey cannot be relied upon

The Corruption Perceptions Index has received criticism over the years. The main one stems from the difficulty in measuring corruption, which happens behind the scenes. The Corruption Perceptions Index, therefore, needs to rely on the third-party survey which has been criticized as potentially unreliable. Data can vary widely depending on the public perception of a country, the completeness of the surveys and the methodology used. The second issue is that data cannot be compared from year to year because Transparency International uses different methods and samples every year. This makes it difficult to evaluate the result.

Another issue is historically funded since its inception in 1993 by large multinationals – Exxon/ Mobil, Shell, and Hedge Fund KKR being the most significant donors. One cannot help but question the objectivity of the survey with large private donors.

TI’s International Board of Directors reacted to this conflict of interest by stripping its US affiliate – Transparency International USA – of its accreditation as the National Chapter in the United States.

TI Headquarters reported that TI-USA came to be seen in the United States as a corporate front group, funded by multinational corporations given the large donor base.

Secondly, the surveys themselves are conducted by organizations such as Freedom House, which have known biases. In August 2019 whistleblower accounts from seven current and former TI Secretariat staff emerged, describing a “toxic” workplace culture under the current Managing Director, Patricia Moreira. Reported in The Guardian, the misconduct reported ranged from gagging orders in termination agreements to bullying and harassment of critical internal voices.

Although the Corruption Perception Index remains popular with its audience as it is unveiled each year, it becomes more clear after digging deeper into Transparency International why there’s not a more robust correlation between FCPA Violations as identified by the SEC and DOJ and the faltered Corruption Perception Index. In addition, the index is not relied on by any public or private enforcement agency for compliance purposes. If anything it brings to light an unconscious or conscious bias against certain developing countries. One can argue its prejudice.

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Frank is an accomplished Senior Finance Executive and Board Member with more than 25 years of success in the pharmaceutical, medical devices, contract manufacturing, and healthcare industries. Leveraging extensive experience leading manufacturing, operational, and financial strategies across 35 countries. Frank has also implemented over 30 FCPA Compliance/ Controls Remediation and Certification Programs across 25 countries.

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The Corruption Index: An In-Depth Look at What it Means & How it Relates to FCPA

December 14th, 2019 Frank Orlowski Leave a comment

The Corruption Perceptions Index (CPI) is an index published annually by Transparency International since 1995 which ranks countries “by their perceived levels of corruption, as determined by “expert assessments” and opinion surveys.

The CPI currently ranks 176 countries “on a scale from 100 (very clean) to 0 (highly corrupt).” Denmark and New Zealand are perceived as the least corrupt countries in the world, ranking consistently high among international financial transparency, while the most perceived corrupt country in the world is Somalia, ranking at 9–10 out of 100 since 2017.

This short video link below provides an overview of the Corruption Perception Index.

One could argue that there could be a direct correlation between the number of FCPA Violations and how high a country ranks on the Corruption Perception Index (CPI). Upon analysis, there is no such correlation and therefore the reliance by Chief Compliance Officers on the CPI as published each year by Transparency International comes into question

Upon further investigation of the survey developers – Transparency International (TI) based in Berlin Germany, it becomes clearer why the survey cannot be relied on.

The Corruption Perceptions Index has received criticism over the years. The main one stems from the difficulty in measuring corruption, which by definition happens behind the scenes. The Corruption Perceptions Index, therefore, needs to rely on third-party surveys which have been criticized as potentially unreliable. Data can vary widely depending on the public perception of a country, the completeness of the surveys and the methodology used. The second issue is that data cannot be compared from year to year because Transparency International uses different methodologies and samples every year. This makes it difficult to evaluate the result of the new policies.

Another issue is historically been funded since its inception in 1993 by large multinationals – Exxon/ Mobil, Shell, and Hedge Fund KKR being the largest donors. One cannot help but question the objectivity of the survey with large private donors. TI’s International Board of Directors reacted to this conflict of interest by stripping its US affiliate – Transparency International USA – of its accreditation as the National Chapter in the United States and it was reported by TI Headquarters that TI-USA came to be seen in the United States as a corporate front group, funded by multinational corporation given the large donor base.

Secondly, the surveys themselves are conducted by organizations such as Freedom House, which have known biases. In August 2019 whistleblower accounts from seven current and former TI Secretariat staff emerged describing a “toxic” workplace culture under the current Managing Director, Patricia Moreira. Reported in The Guardian, the misconduct reported ranged from gagging orders in termination agreements to bullying and harassment of critical internal voices

Hughes Hubbard Releases 2022 FCPA Alert

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