The United States will host the 10th session of the Conference of the States Parties (COSP) to the United Nations Convention against Corruption (UNCAC) in Atlanta from December 11-15, 2023.

n a speect to the 40th International Conference on the Foreign Corrupt Practices Act, the Justice Department's FCPA Chief announced an anti-bribery initiative to drive cross-border collaboration in fighting foreign bribery. Acting Assistant Attorney General Nicole Argentieri's comments included the announcement of the International Corporate Anti-Bribery initiative, or ICAB, which will be driven by three experienced prosecutors, who will build on existing bilateral and multilateral partnerships, as well as form new partnerships.

A Virginia tactical gear and equipment company agreed to pay nearly $2.1 million to resolve False Claims Act allegations that it failed to comply with the requirements of the Buy American Act, Trade Agreements Act and Berry Amendment when selling textile-based products to the Department of Defense.The company marketed its goods as “100% made in America” and replaced the original foreign manufacturers’ tags with tags that read “Made in USA.”

The Public Company Accounting Oversight Board sanctioned PwC China and PwC Hong Kong for violating PCAOB quality control standards related to integrity and personnel management. Both firms failed to detect or prevent extensive, improper answer sharing on tests for mandatory internal training courses. The PCAOB also sanctioned the accounting firm Haoxin and four of its associated persons for violations of the U.S. securities laws and PCAOB rules and standards in connection with the audits of the 2015-2017 financial statements of Gridsum Holding Inc.

Two Texas men were convicted at trial on Nov. 15 on charges of attempting to violate the International Emergency Economic Powers Act (IEEPA), conspiracy to violate IEEPA, and conspiracy to commit money laundering in connection with their attempt to transact in sanctioned Iranian petroleum and launder the proceeds. According to evidence presented at trial, in 2019 and early 2020, Zhenyu “Bill” Wang and Daniel Ray Lane engaged in a conspiracy to purchase petroleum from Iran, in violation of economic sanctions imposed by the United States under IEEPA. They then planned to mask the origins of the petroleum and sell it to a refinery in China. The defendants also attempted to conceal their illegal transactions by obtaining foreign passports, engaging in sham contractual agreements, and conspiring to launder the proceeds of the sale through shell entities and offshore financial accounts.

Two U.K.-based reinsurance brokers have agreed to resolve investigations by the Justice Department into violations of the Foreign Corrupt Practices Act (FCPA) arising from a corrupt scheme to pay bribes to Ecuadorian government officials.  Tysers and H.W. Wood each entered into a three-year deferred prosecution agreement (DPA) with the department in connection with a criminal information filed in the Southern District of Florida charging both companies with conspiracy to violate the anti-bribery provisions of the FCPA. 

Binance Holdings Limited (Binance), the entity that operates the world’s largest cryptocurrency exchange, Binance.com, pleaded guilty and has agreed to pay over $4 billion to resolve the Justice Department’s investigation into violations related to the Bank Secrecy Act (BSA), failure to register as a money transmitting business, and the International Emergency Economic Powers Act (IEEPA) Binance’s founder and chief executive officer (CEO), Changpeng Zhao, a Canadian national, also pleaded guilty to failing to maintain an effective anti-money laundering (AML) program, in violation of the BSA and has resigned as CEO of Binance.

On November 16, 2023, the U.S. Department of Justice (DOJ) issued a letter to Lifecore Biomedical, Inc., formerly known as Landec Corporation, under the agency's Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy. This letter was a "declination with disgorgement," [link] indicating that the DOJ decided not to prosecute Lifecore despite identified misconduct. The situation involved FCPA violations by Lifecore’s former subsidiary, Yucatan Foods. It was found that employees and agents of Yucatan Foods had engaged in bribery, specifically paying bribes to Mexican government officials to secure a wastewater discharge permit.

Aircraft parts suppliers to the Maduro Regime and Indian semiconductor distributors trading with Russia were the subject of regulatory actions last week, while Uncle Xi's promise of help with our Fentanyl problem got a state forensic lab off the blacklist.

OFAC settled with daVinci Payments Nov. 6 for its violations of sanctions with Crimea, Cuba, Iran and Syria.

U.S. Customs and Border Protection officers seized a shipment of China-bound deuterium cylinders in Norfolk on October 18 for violating nuclear nonproliferation licensing laws. On August 22, CBP’s National Targeting Center (NTC) identified the deuterium on the manifest of a shipping container destined to China. CBP officers detained the deuterium, and the following day requested a licensing determination from the Bureau of Industry and Security. 

Commerce’s Bureau of Industry and Security (BIS) announced the imposition of a civil penalty of $44,750 against Forta LLC (Forta), a manufacturer of synthetic reinforcement fibers, located in Grove City, Pennsylvania, to resolve three violations of the antiboycott provisions of the Export Administration Regulations (EAR, 15 C.F.R. parts 730-774) (antiboycott regulations). Forta voluntarily disclosed the conduct to BIS, cooperated with the investigation by BIS’s Office of Antiboycott Compliance (OAC), and took remedial measures after discovering the conduct at issue, all of which resulted in a significant reduction in penalty.

Four individuals were arrested, and an indictment and criminal complaint were unsealed this week regarding two separate conspiracies to unlawfully export controlled, dual-use technologies to Russia. October 31, a criminal complaint was unsealed, and a Brooklyn, New York, resident and two Canadian nationals were arrested in connection with a global procurement scheme in which the defendants used two corporate entities registered in Brooklyn to unlawfully source and purchase dual-use electronics on behalf of end-users in Russia, including companies affiliated with the Russian military. Separately, a Brooklyn resident was arrested, and a four-count indictment was unsealed alleging an illegal exports scheme to procure dual-use electronic components for entities in Russia involved in the development and manufacture of drones for the Russian war effort in Ukraine.

GE Healthcare Technologies, a spinoff of General Electric, has reported potential violations of the Foreign Corrupt Practices Act (FCPA) in its China-based operations. The disclosure was made in the company's quarterly filing with the United States Securities and Exchange Commission (SEC) on Ootober 31. According to the filing, GE Healthcare identified "tender irregularities and other potential violations" related to its activities across multiple Chinese provinces. This marks the first instance that the company has publicly acknowledged possible FCPA violations.

  The Federal government announced the filing of a civil forfeiture complaint against the Motor Yacht Amadea, a 348-foot luxury vessel reportedly worth over $300 million.   The Complaint alleges that the superyacht, which is beneficially owned by Russian oligarch Suleiman Kerimov, was improved and maintained in violation of applicable sanctions against Kerimov and those acting on his behalf.

FinCEN has identified the following red flag indicators to help detect, prevent, and report potential suspicious activity related to Hamas’s terrorist financing activity. As no single red …

The OECD Released its Phase 4 Report on Brazil's implementtion of the Anit-Bribery Convention October 17.  This report details Brazil's achievements and challenges in respect to implementation and enforcement of the OECD Anti-Bribery Convention, as well as progress made since the Phase 3 evaluation in 2014.

A U.S. citizen residing in the Principality of Monaco pleaded guilty to tax evasion for concealing from the IRS over $5,130,000 in income derived from a real estate transaction and securities investments in offshore bank accounts.

A Florida husband and wife, Noel and Kelsy Hernandez Quintana, pleaded guilty to conspiring to import plywood contrary to the Lacey Act and customs laws, and to selling plywood products that were …

The US. State Department and Federal Bureau of Investigation, in coordination with partners from the Republic of Korea Ministry of Foreign Affairs, National Police Agency, and National Intelligence Service are releasing a joint public service announcement (PSA)  with updated guidance on red flag indicators and due diligence measures to help companies avoid hiring Democratic People’s Republic of Korea (DPRK) information technology (IT) workers posing as non-DPRK nationals. This update identifies new tradecraft used by DPRK IT workers since the release of the 2022 advisories, including new indicators of potential DPRK IT worker activity and additional due diligence measures the international community, private sector, and public can take to prevent the hiring of DPRK IT workers.

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