In a recent case the DOJ dubbed a “wake-up call,” the SEC and DOJ charged four individuals for their roles in a massive international bribery scheme, which the SEC discovered during a periodic examination of a broker-dealer. The agencies allege that employees of Direct Access Partners, LLC (“DAP”), a registered broker dealer, paid illicit bribes to high-ranking officials of Banco de Desarrollo Economico y Social de Venezuela (“BANDES”), the state-owned economic development bank of Venezuela. The action illustrates how conduct that has traditionally formed the basis of a Foreign Corrupt Practices Act (“FCPA”) case might also subject individuals and entities to a much broader array of charges under US law, including charges under anti-money laundering laws and the Travel Act.
Join an experienced panel of government enforcement experts to learn how multi-national organizations in all industries can ensure that they have developed and implemented robust compliance programs that address these overlapping regulatory schemes.
- Jeffrey Lehtman, Partner, Allen & Overy
- Kurt Wolfe, Associate, Allen & Overy
- Sarah Cox, Associate, Allen & Overy
- Ellen Zimiles, Managing Director, Head of Global Investigations & Compliance, Navigant, Inc.
- Alma Angotti, Director, Global Investigations & Compliance, Navigant, Inc.
- Jay Perlman, Director, Global Investigations & Compliance, Navigant, Inc.