Tag: James Koukios

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FCPA Compliance Report

James Koukios on MoFo March International Anti-Corruption Newsletter


In this Episode of the FCPA Compliance Report, I am joined by fan fav James Koukios to review the Morrison & Foerster March International Anti-Corruption Newsletter.  Highlights of this podcast include:

  1. Scottish Oil and Gas Company Resolves Kazakhstan Bribery Allegations in Scotland. Why is Scotland prosecuting compliance?
  2. UK Serious Fraud Office Ends Foreign Bribery Investigation into KBR.
  3. UK to Launch Corruption Sanctions Regime in 2021. What does it mean for US or other non-UK companies?
  4. Former CFO of New York-Based Hedge Fund Ordered to Pay Civil Penalty. Follow on from Och-Ziff, what is that case’s legacy?
  5. Oil Companies Acquitted in Italy over Nigeria Deal. Use to explore the prosecution’s theory of liability and how that could change compliance.

Resources 
James Koukios on the Morrison & Foerster website
MoFo March International Anti-Corruption Newsletter here.

Categories
FCPA Compliance Report

James Koukios on MoFo January and February Int’l ABC Newsletter


In this Episode of the FCPA Compliance Report, I am joined by fan fav James Koukios, partner at Morrison & Foerster and editor of the firm’s great monthly International Anti-Corruption Developments Newsletter. In this episode we look back to some of the key developments from the January and February newsletters.
Highlights include:

  • 2021 TI-CPI released. What value do you see in it? Do compliance professionals rely too greatly on it to determine an appropriate level of due diligence?
  • Samir Khoury denied cert. How or why could an indictment go unsealed for 10 years?
  • Daniel Comoretto pleads guilty. Follow on from Sargeant Marine FCPA enforcement action.
  • KBR decision. What does it mean for the SFO?
  • Samsung Industries resolves corruption matter thru Leniency Agreement.
  • Paul Bond convicted on retrial.
  • Spain extradited Alonso Ancira to Mexico. What if any is the significance to this action?
  • Car Wash ends. How would you assess its overall impact on the global fight against bribery and corruption?

Resources 
January International Anti-Corruption Developments
February International Anti-Corruption Developments
James Koukios on MoFo

Categories
FCPA Compliance Report

James Koukios on MoFo Top 10 Int’l ABC Developments for December 2020

In the Episode, fan fav and MoFo partner James Koukios returns to discuss the firm’s always informative Top 10 International Anti-Corruption Developments for December 2020. We focus this episode on ABC enforcement efforts from other countries. Highlights include:

·       CFTC brings first FCPA enforcement action;

·       Patrick Ho conviction upheld;

·       Brazilian government announces 5-year ABC plan;

·       MPP settles Car Wash enforcement action; and

·       ABC reforms introduced in NDAA.

Recourses
MoFo Top 10 International Anti-Corruption Developments for December 2020

Categories
FCPA Compliance Report

James Koukios on MoFo Top 10 Int’l ABC Developments for November 2020


In the Episode, fan fav and MoFo partner James Koukios returns to discuss the firm’s always informative Top 10 International Anti-Corruption Developments for November 2020. We focus this episode on ABC enforcement efforts from other countries. Highlights include

  • OECD Reports lauds US enforcement efforts and increased enforcement efforts by the Netherlands;
  • World bank debars German firm;
  • Developments in Mexico;
  • Developments in and concerning Venezuela; and
  • China and its repatriation of fugitives.

Recourses
MoFo Top 10 International Anti-Corruption Developments for November 2020

Categories
FCPA Compliance Report

James Koukios on the MoFo Top 10 International Anti-Corruption Developments for April 2020


In the Episode, I visit with James Koukios, partner at Morrison & Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 International Anti-Corruption Developments for April 2020.
Some of the highlights include:

  1. DOJ Announces Repatriation of $300 Million to Malaysia in Connection With 1MDB.
  1. Colombia Officially Enters the OECD. What was the process and what does this mean for Colombia?
  2. What is the DOJ saying around FCPA enforcement in the Covid-19 era?
  3. London court discharges 3rd ever unexplained wealth order?
  4. ENI resolves Algeria FCPA allegations.

 Resources
To a copy of the Top 10 International Anti-Corruption Developments for April 2020 Newsletter click here.

Categories
FCPA Compliance Report

James Koukios on the MoFo Top 10 International Anti-Corruption Developments for March 2020


In the Episode, I visit with James Koukios, partner at Morrison & Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 International Anti-Corruption Developments for March 2020.
Some of the highlights include:

  1. Portugal Freezes Assets of Africa’s Richest Woman-could this be even bigger than 1 MDB?
  2. Thoughts on Teva FCPA enforcement action in the context of it completing its DPA.
  3. What is the DOJ saying around FCPA enforcement in the Covid-19 era? (IE., any change in enforcement cadence)
  4. What significance, if any, do you see in Mexico request to extradite former Pemex official?
  5. OECD Expresses Concern over Costa Rica’s Foreign Bribery Enforcement Record. What does this mean?

 Resources
To a copy of the Top 10 International Anti-Corruption Developments for March 2020 Newsletter click here.

Categories
FCPA Compliance Report

Episode 457-James Koukios on October MoFo’s International Anti-corruption developments

In the Episode, I visit with James Koukios, a partner at Morrison and Foerster in Washington DC. Koukios is a former prosecutor from the Department of Justice who worked in the FCPA Unit. He is back to discuss the firm’s monthly newsletter the Top 10 International Anti-Corruption Developments for October 2019.
Some of the highlights include:

  • The DOJ Issues Guidance on Corporate Inability-to-Pay Claims. We consider is this something new or codification of prior practices?
  • The Unaoil guilty pleas. Are they huge, even bigger than Panalpina?
  • The EU whistleblower initiative. Is this a sea change or something else? What might it mean for anticorruption enforcement?
  • OECD Expresses Concern over Brazil’s Foreign Bribery Enforcement. Has there been a change in Brazil enforcement or is this simply a part of the natural ebb and flow of enforcement actions?
  • Are things really going to heat up in Mexico in terms of investigations involving Pemex? Should US companies which have done business in Mexico be scrubbing their operations?

Resources
To see the firm’s Top 10 International Anti-Corruption Developments for October 2019, click here.

Categories
FCPA Compliance Report

James Koukios on the Morrison and Foerster Top 10 International Anti-Corruption Developments for April 2019

In this episode I visit with podcast favorite Morrison and Foerster partner James Koukios on the firm’s Top 10 International Anti-Corruption Developments for April 2019. We look at some of the key international developments.  Highlights from the podcast include:

  1. The debate Over Meaning of “Agent” Under FCPA Intensifies Ahead of Hoskins Trial.
  2. Federal Court Finds FCPA Investigation Documents Protected by Attorney-Client Privilege.
  3. International Maritime Organization (IMO) Sets Anti-Corruption Agenda.
  4. We take a deep dive into the new Evaluation of Corporate Compliance Programs, 2019 Guidance. What is new (if anything)? How does this assist the corporate compliance professional? Should it be read in conjunction with the Benczkowski Memo?

To see a copy of the Morrison and Foerster Top 10 International Anti-Corruption Developments for April 2019, click here.

Categories
FCPA Compliance Report

FCPA Compliance Report-Episode 439, James Koukios on the Morrison and Foerster Top 10 International Anti-Corruption Developments for March 2019

In this episode I visit with podcast favorite Morrison and Foerster partner James Koukios on the firm’s Top 10 International Anti-Corruption Developments for March 2019. We look at some of the key international developments.  Highlights from the podcast include:

  1. The MTS FCPA Settlement.
  2. Changes in FCPA Corporate Enforcement Policy-what is ‘De-Confliction’ and ephemeral messaging.
  3. OECD Working Group on Bribery Reports on the UK’s Foreign Bribery Enforcement Record.
  4. CFTC announces entry into FCPA enforcement.
  5. India appoints first anticorruption ombudsman.

To see a copy of the Morrison and Foerster Top 10 International Anti-Corruption Developments for March 2019, click here.

Categories
FCPA Compliance Report

FCPA Compliance Report-Episode 429, James Koukios on MoFo’s February Anti-Corruption Newsletter

In this episode I have back with me, fan favorite James Koukios, partner at Morrison and Foerster.  This is Part 2 of a two-part series where we discuss the firm’s always great Top 10 International Anti-Corruption Developments newsletter. In this episode, we take a look at some of the key highlights from the February newsletter. In the most recent episode, we detailed some of the key developments from the January newsletter. We also have a special segment on the FCPA Opinion Release Procedure. Some of the highlights from the podcast include:

  • DOJ Files $38 Million Civil Forfeiture Action in Connection with Malaysia Sovereign Wealth Fund Scandal
  • What is the role of civil forfeiture in anti-corruption enforcement?
  • 9thCircuit Court of Appeals Vacates Federal Whistleblower Retaliation Verdict Against Bio-Rad. What does this mean for whistleblower cases going forward?
  • UK Serious Fraud Office Closes Two Foreign Bribery Cases. Gutless move on the part of the new director or is something else going on?
  • What is the Opinion Release Procedure? How a company can use it? What happens on the DOJ side once a request comes into the DOJ?

For further reading, see the Morrison and Foerster Top 10 International Anti-Corruption Developments for February 2019, by clicking here.