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Last month Brazil's new chief prosecutor, Raquel Dodge, was sworn in, replacing the very high-profile Rodrigo Janot. From Janot she inherits a number of high profile cases, including one filed during his last days in office against Brazil's President, Michel Temer, on charges stemming from the huge "Operation Car Wash" scandal. (We've talked about Operation Car Wash before.) Dodge said in her inaugural address that "no one is above the law and that no one is below the law" and she stressed that Brazilians today “do not tolerate corruption and not only expect, but demand, results.”

We were saddened to see that Daphne Caruana Galizia, a journalist who focused on corruption in Malta, was killed in a car bomb attack.She was extremely well known and popular in Malta. Her blog entries sometimes attracted more readers than the combined circulation of Malta's newspapers. The website Politico has described here as "a one woman wiki leaks."

It's not enough to avoid risky behavior in your own business, it's important to take the time to check on your business partners, vendors, and even clients to be sure they aren't engaging in risky behavior either. Federal regulators with the Financial Crimes Enforcement Network (FinCEN) recently fined a small Texas bank for violations of the Bank Secrecy Act for a failure to conduct requisite due diligence and a lack of controls on foreign accounts.

Hello and welcome to the new SBI blog, we hope you enjoy it! We’re going to use it to keep you up to date on the latest news from SBI, highlight some of our services, and provide our thoughts on the news and other topics related to our work.

A year on from the disclosure of the Panama Papers, revelations continue to trickle to the surface. In April the International Consortium of Investigative Journalists added two world leaders to their Power Players list: Australian Prime Minister Malcom Turnbull and former Mongolian Prime Minister Sükhbaataryn Batbold were both revealed to have interests in separate offshore companies connected to mining operations in central Asian.

International business environments are always in a state of flux, and it’s not always easy to figure out the implications for your business. Whether it’s a corruption scandal in Brazil, currency changes in India, or renewed sanctions on Russia, local issues can often have an unexpected impact on your international operations.

On June 5th, 2017, in a case with implications for complex fraud and corruption investigations, the US Supreme Court ruled to limit the Security and Exchange Commission’s power to recover ill-gotten gains. The case (Kokesh v. SEC) hinged on whether SEC disgorgements should be considered a “fine, penalty, or forfeiture,” or whether they are instead a remedial tool. In a unanimous decision, the Justices ruled that SEC disgorgement “bears all the hallmarks of a penalty,” and is therefore subject to a five-year statute of limitations as laid out in 28 USC § 2462.

Corruption and bribery are unfortunately all too common in the business world. But thankfully, enforcement of anti-corruption laws is also on the rise. Recently, the Brazilian construction firm Odebrecht received the largest ever corruption related fines in history.

Christopher Wray, the nominee for the Directorship of the FBI has a history of work on white collar crimes including FCPA and trade sanctions violations and money laundering. During his time as United States Assistant Attorney General for the Criminal Division from 2003 to 2005, much of his work focused on white collar crime. After leaving the DOJ he continued to work on white collar crime, government investigations, and regulatory issues at the law firm King & Spalding.

Money laundering is a serious issue that impacts businesses, large and small, all over the world. Money laundering, simply put, is the act of making illegitimate funds appear to come from legitimate sources. Businesses that deal in high volumes of cash, such as restaurants, are most commonly used to launder money, though any kind of business, including those that deal in electronic payments can be used for money laundering.

Here at Smith Brandon, we’ve been following the 1MDB scandal with great interest. The sheer scale of funds misappropriated from the beleaguered Malaysian sovereign wealth fund is just staggering; estimates peg it at roughly $4.5 billion. Recently, three new revelations came to light.

A year and a half after the release of the Panama Papers, another large data leak regarding offshore entities has been published. In November 2017 the International Consortium of Investigative Journalists released the Paradise Papers in cooperation with the German newspaper Süddeutsche Zeitung. The Paradise Papers primarily consist of documents leaked from the prominent offshore law firm Appleby, and contains names of more than 120,000 people and companies with holdings in offshore tax havens.

We’ve talked about the Panama Papers before, but the changes they are bringing to the international political landscape are still taking shape. Last week, the Panama Papers led to the fall of another world leader.

A new anti-corruption committee has been established in Saudi Arabia, which has the power to conduct investigations, make arrests, issue travel bans, and freeze assets of individuals and companies. This committee is headed by Crown Prince Mohammed Bin Salman, son of King Salman bin Abdulaziz Al-Saud. However, rather than instilling confidence in foreign investors this anti-corruption committee has led to some uncertainty and confusion in Saudi business circles.

We are approaching the 40th anniversary of the enactment of the Federal Corrupt Practices Act (FCPA). The Department of Justice has released new guidance to further encourage companies to voluntarily disclose FCPA violations.

We talk a lot about the FCPA and US anti-corruption and anti-bribery laws, but other countries have their own sets of anti-corruption laws that firms have to keep in mind. In Canada the Corruption of Foreign Public Officials ActCorruption of Foreign Public Officials Act (CFPOA) is often referred to as the Canadian FCPA. This law impacts not just Canadian businesses but any business that engages activity in and with Canada.

The Financial Crimes Enforecement Network (FinCEN), a division of the Treasury Department, has ordered new reporting and record keeping requirements for some real estate transactions in Honolulu, Hawaii. With this order, Honolulu joins six other areas in what's called a Geographic Targeting Order (GTO). FinCEN also extended the reporting requriments for all areas under GTOs through March of 2018.

Despite common perceptions, public corruption is a problem which plagues even the most developed countries, including the United States. Elected officials can be bribed, as appears to be the case with New Jersey Senator Robert Menendez (D). Wednesday, September 6, 2017 marked the start of the federal case against Menendez, who is one of the highest-ranking Democrats in the US Senate. Menendez is on trial for bribery, and could face a lengthy prison sentence.

Guatemala is currently in political upheaval over a recent events related to anti-corruption efforts in the country. Last month, President Morales tried to expel Ivan Velasquez, the head of a UN commission (The International Commission Against Impunity in Guatemala, or CICIG) set up to expose political corruption in Guatemala. However, the country's top court quickly moved to stop the expulsion. The president has argued that the UN commission violated Guatemala's sovereignty, but protesters and other groups feel that the commission is the country's best hope to curb corruption in the country.

Recently the Swedish Telecom company Telia Company AB has agreed to pay $965 Million in penalties for violating the FCPA. Some of that money will go to Swedish and Dutch prosecutors, with the rest going to the Department of Justice and the SEC. This is, by the reckoning of the authors over at the website FCPA Blog, the largest ever FCPA settlement.

Today brought another big development in the ongoing and multifaceted "Operation Car Wash" anti-corruption investigation that has been going on in Brazil for some time now. We've talked about Operation Car wash a couple of times before. The Brazilian Supreme Court ruled today that former president Luiz Inácio Lula da Silva will be jailed before he can further appeal his corruption conviction.

Keppel Offshore & Marine Ltd. (KOM), a Singapore-based shipyard operator and oil-rig builder, and its wholly-owned US subsidiary Keppel Offshore & Marine USA Inc. (KOM USA) have agreed to pay $422 million in penalties for violations against the US Foreign Corrupt Practices Act (FCPA). These penalties, which will be paid to authorities in the US, Singapore, and Brazil are the result of more than a decade of bribery payments made by KOM and KOM USA to Brazilian officials.

In mid-January 2018, Carillion, the UK’s second largest construction company that provides business support services as well as public services in schools, prisons, hospitals, transportation systems, and ministry of defense sites, announced that it was forced into compulsory liquidation. Carillion, which has debts and liabilities totaling roughly US $3 billion, stated that the company was unable to secure funding to continue its business plan.

Blockchains and cryptocurrencies are a major topic at this year’s World Economic Forum in Davos, Switzerland. While cryptocurrencies such as Bitcoin are not always held in high regard due to their volatility, lack of a supportive financial structure, and history of association with illicit trade, the blockchain, one of the technologies behind bitcoin and other cryptocurrencies, is being hailed by some as a potential tool to increase financial security and transparency.

Australia, like many countries, is looking at overhauling and strengthening its various anti-corruption laws. A number of new laws have been proposed recently that would change the way Australia handles corruption and bribery cases. If adopted these new proposed laws could be a big step toward making action on corruption in Australia much easier and more effective.

We usually comment on news and current events here on the blog, but we'd like to take a moment to point you all to our entry in a recent video contest. We entered a video contest for small businesses (under 50 employees), sponsored by SCORE (a nonprofit organization that provides business mentoring services to entrepreneurs in the US), in partnership with the Small Business Administration (SBA).

In mid-2013 Beijing-based wind turbine manufacturer and exporter Sinovel Wind Group Co. Ltd. (Sinovel) was charged with theft of intellectual property from US energy technology company AMSC, formerly American Superconductor Inc.

In January 2016, the UN started to remove some of the sanctions imposed on Iran, related to the country’s nuclear program and uranium-enrichment program. The sanctions were eased as a result of the Joint Comprehensive Plan of Action (JCPOA) that was reached by the EU, the US, China, Russia, and Iran on July 14, 2015.

We just wanted to alert everyone to a new scam going around in which the scammers pretend to be representing or to have some affiliation with FINRA, the Financial Industry Regulatory Authority. The letters offer fake investment opportunities and use the FINRA Logo, a lot of legal sounding language, and even a fake signature from the FINRA President and CEO to try to make them look more official. The letters falsely claim that FINRA is backing or "guaranteeing" these investments.

While our focus is generally on the more traditional business world, today we have an example of corruption and bribery from the world of college sports. This story also serves as a good example of the ways that the repercussions of bribery and corruption are not always limited to legal proceedings or prosecutions. The repercussions and impact on business and organizations can be wide-reaching, and can hit in unexpected ways.

While often this blog focuses on corruption and fraud, we also pay close attention to international news generally, so we can be sure we’re prepared for any issues that may come up for our clients. One situation we’ve recently been following is the relationship between the UAE and Somalia.

Park Geun-hye, the disgraced former president of South Korea, will not appeal her 24-year prison sentence for bribery, corruption, and extortion. This announcement, made on April 16, ends what has been one of the biggest political scandals in South Korean history. A scandal which has shined a light on government and corporate corruption in the nation.

Smith Brandon International frequently works for our clients in India. So we keep a close eye on the country to make sure we're always up to speed on what's happening there, and how it might effect our clients. Recently, India’s banking fraud problem has become so severe, some economic experts warn that it may hamper the country’s economic growth and development.

Egbert Koolman, a current resident of Florida and former official at the Aruban state-owned telecommunications company Servicio di Telecommunicacion di Aruba N.V. (Setar), has recently plead guilty in a money laundering and bribery scheme that also led to guilty pleas for FCPA violations from others involved in the scheme.

Here on the blog we've discussed the 1MDB scandal before before in Malaysia. First reported on in 2015, the scandal involves some US $4.5 billion that was allegedly misappropriated from a government-owned fund.

It’s always important to hire the right person for the job. But the recent resignation of luggage-maker Samsonite’s CEO, Ramesh Tainwala, serves as a high-profile reminder that resumes sometimes fail to reflect reality.

Ousting corrupt heads of government has slowly become more common across the world. In 2016, major corruption scandals and nation-wide political protests led to the impeachment of the Presidents of Brazil and South Korea. In 2017, the release of the Panama Papers led to the resignation of the Prime Minister of Iceland and the dismissal of the President of Pakistan. Now, a corruption case almost a decade in the making has unseated the Prime Minister of Spain.

The US Department of State recently granted an extradition request filed by the government of Panamanian President Juan Carlos Varela to extradite his predecessor – former President Ricardo Martinelli (2009 – 2014), often described as a supermarket tycoon. The extradition request appears to focus primarily on allegations of illegal surveillance and political espionage during Martinelli’s presidential term.

Recently there was a new round of leaks from Mossack Fonseca, the law firm at the center of the Panama Papers leak that happened several years ago. We’ve covered the Panama Papers several times here on the blog. These latest leaks, of internal company emails and other documents, don’t just add more names and companies to those already leaked, they also give a lot more detail on the practices of this law firm, and the chaos inside the firm after the initial leak, and the eventual demise of Mossack Fonseca.

Over on FCPA Blog they've published an article we wanted to be sure our readers saw. The article comes from Felipe Monteiro a Professor at INSEAD, who has written a case study on the implications of Operation Car Wash for Brazilian businesses. The article on FCPA blog details lessons learned from Brazil's Operation Car Wash, based on comments from Judge Sergio Moro, who has jailed many of those prosecuted by the operation.

Recently authorities in Cambodia seized fake and expired pharmaceuticals from an importer, US authorities charged 22 Chinese importers with smuggling counterfeit goods, including cosmetics and luxury hand-bags, and Singaporean police raided four businesses with $1.03 Million in goods as part of an operation against counterfeit products.These are just a few recent examples, but there are many more. And these are just the cases that have been found out.

Update: We wanted to provide a short update on the results of the election. As expected, Bolsonaro won the most votes, though not enough to win outright, though he came surprsingly close. Despite there being a small fine for not voting in Brazil, almost a third of voters either didn't vote in the last round of the elections or cast blank or null ballots.

The United States Census Bureau performs a vital service for the United States, surveying the population to make sure the government has accurate information on the people it represents and helps to direct government spending and programs. To that end they ask a lot of different kinds of questions in their official surveys.

The United Nations recently marked World Anti-Corruption Day. In announcing the day the UN highlighted the current estimate that every year over $1 Trillion is paid in bribes and over $2.6 Trillion is stolen through corruption. That's over 5 percent of the worlds gross domestic product. An astonishing figure.

The International Commission Against Impunity in Guatemala (CICIG) has been the subject of recent media reporting as the current President of Guatemala, Jimmy Morales, prematurely ordered the shut down of the Commission in early January. CICIG was expected to conclude its operations in September 2019 as President Morales had declined to further renew its mandate.

While we’ve previously written about the uncertainties of international trade involving Iran, we’re currently monitoring a new wrinkle. On January 31, 2019, the Foreign Ministers of France, Germany, and the UK announced the creation of INSTEX (Instrument in Support of Trade Exchanges), a special purpose vehicle (SPV) designed to facilitate European trade with Iran. The SPV is expected to begin operating within the next few months.

We've written before about Malaysia's 1Malaysia Development Berhad (1MDB) fund and the scandals associated with it. The corruption from the scandal just keeps ensaring more people and organizations through out the world. Recently Tim Leissner, former Goldman Sachs Chairman in Southeast Asia pleaded guilty to money laundering conspiracies in connection with the 1MDB fund. Several other employees were also implicated in that plot.

Ukrainian President Petro Poroshenko (Petro Poroshenko Bloc “Solidarity” / BPP-S Political Party) has been the subject of recent reporting by investigative journalists that identified Poroshenko as allegedly tied to a corrupt defense scheme pertaining to contraband military parts. As a result, the initiation of impeachment proceedings were announced against Poroshenko in Ukraine’s Parliament.

Corporate lending growth in the euro zone rebounded last month, European Central Bank data showed on Thursday...

Russia’s manufacturing PMI climbed to its highest level since January 2017 registering 52.8 in March, up from almost no change of...

LOS ANGELES/DUSSELDORF, April 2 (Reuters) - The volume of U.S. ocean cargo imports arranged by Deutsche Post’s DHL Group...

WASHINGTON (Reuters) - New orders for key U.S.-made capital goods slipped in February and shipments were unchanged, but data for...

In March 2019, Transparency International Canada released a comprehensive new report, in conjunction with Publish What You Pay Canada...

Yesterday the Department of Justice announced the release of updated guidance on corporate compliance programs. We are still evaluating the new guidance and what has changed, but we wanted to be sure all of our clients and readers were aware that there is new information from the DOJ on what compliance programs should look like and how they should work.

You have a questionnaire. You’ve conducted due diligence. Your research of beneficial ownership just hit a dead end. Now what?

We were recently made aware of a new twist on a common scam and want to be sure our readers are aware of it.

Two years ago, we wrote about the murder of Maltese journalist, Daphne Caruana Galizia, known for her work on Maltese corruption. While three men suspected of planting the car bomb that killed her were arrested shortly after her death in 2017, until recently little progress had been made regarding the identity of the person or persons who hired them.

The U.S.-China trade dispute escalated sharply Monday, as Beijing retaliated against higher U.S. tariffs with plans to increase levies on...

Here at Smith Brandon International, we watched with some interest the recent conviction of con artist Anna “Delvey” Sorokin. For years, the Russian-born Ms. Sorokin claimed to be a German heiress, situating herself within New York’s wealthy party circles while seeking funding for a private club and arts foundation.

In early April of this year Algerian President Abdelaziz Bouteflika resigned from office after ruling for roughly 20 years. Bouteflika’s resignation is reportedly a result of peaceful protests and pressure from Algerian military leaders in response to Bouteflika’s announcement that he would be seeking a fifth presidential term. The protests in Algeria have been ongoing since mid-February 2019, and more recently have been occurring on a weekly basis.

On May 2, 2019 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released “A Framework for OFAC Compliance Commitments”.

European markets were cautious on Tuesday as the dust settled on last week’s rally and concerns over a trade war tempered gains.

Our client, NXT Energy Solution, was recently featured in BusinessInsider.com for being awarded a major contract in Nigeria.

The Securities and Exchange Commission charged Syed Arham Arbab with conducting a Ponzi scheme from a University of Georgia fraternity house.

The General Services Administration will administer a virtual meeting July 25 with current and potential government contractors to discuss...

Despite well-documented missteps in Germany and South Korea, the late 2000’s were a dynamic time for Wal-Mart’s expansion efforts worldwide.

Despite well-documented missteps in Germany and South Korea, the late 2000’s were a dynamic time for Walmart’s expansion...

A trade spat between Japan and South Korea threatens to spill beyond their borders, posing potential risks to consumer electronics...

Top trade negotiators from the US and China are meeting for the first time in almost three months on Tuesday to try and do a deal, but expectations are low.

Recently, the local Zimbabwe branch of Amnesty International, a UK-based international non-governmental rights advocacy group, was suspended indefinitely following fraud allegations.

A scandal pertaining to the theft of rare and precious kevazingo wood seized by Gabon officials has allegedly resulted in the termination of the Vice President of Gabon as well as the Forestry Minister.

The Federal Trade Commission announced a staggering $5 billion dollar civil penalty against Facebook.

On January 12, 2016, an all too familiar story appeared in Youngstown’s Business Journal: Warren Steel Holdings LLC would...

Asia markets joined a global sell-off as fresh worries about trade and the world economy rattled investors.

If the U.S. economy is headed for a significant slowdown, nobody told the American consumer...

In a memorable 2007 episode of Curb your Enthusiasm, titled “The Anonymous Donor,” Larry David attends a gala honoring his and another major donation made to the National Resources Defense Council.

U.S. and China trade representatives will end years of intense bilateral negotiations with a “phase one” deal on Wednesday that promises...

While many industries have become fixated with the potential of AI – including the field of corporate Due Diligence.

CINCINNATI, Jan. 28, 2020 /PRNewswire/ -- The Kreller Group today announced its acquisition of Smith Brandon International, Inc. (SBI), a corporate investigations and risk consulting firm based in Washington, D.C. SBI will now be known as Smith Brandon International, a Kreller Company. The SBI entire SBI team is staying on, and SBI will continue to operate out of its Washington, DC office.

The Kreller Group today announced its acquisition of Smith Brandon International, Inc. (SBI).

As Chinese manufacturing hits a record low amid coronavirus disease concerns*, American companies are forced to look elsewhere for product and component sourcing.

We all encounter the problem of knowing who we’re working with. Whether it’s our business partners, vendors, or clients, it’s difficult to know anyone.

The Uyghur Forced Labor Prevention Act would require any importer of Xinjiang-sourced products to prove they were not made using forced labor.

Public funds reportedly spent on items such as luxury yachts, private jets, and a diamond-encrusted glove worn by Michael Jackson prompted the UK Foreign Office to impose new sanctions.

Public funds reportedly spent on items such as luxury yachts, private jets, and a diamond-encrusted glove worn by Michael Jackson prompted the UK Foreign Office to impose new sanctions.

Public funds reportedly spent on items such as luxury yachts, private jets, and a diamond-encrusted glove worn by Michael Jackson prompted the UK Foreign Office to impose new sanctions.

In 2020, a list of over 50,000 phone numbers was leaked to Amnesty International and Forbidden Stories, a nonprofit media organization based in Paris, France. The numbers are believed to belong to individuals identified as "people of interest" by clients of the Israeli cyber defense firm NSO Group. The leak set off a worldwide investigative journalism initiative – the Pegasus Project.

Breaking into new markets and winning major government contracts can be a daunting task for even the largest corporations, doubly so in emerging markets that are in political transition or have gone through a recent major upheaval.

Public funds reportedly spent on items such as luxury yachts, private jets, and a diamond-encrusted glove worn by Michael Jackson prompted the UK Foreign Office to impose new sanctions.

Data science has reshaped many industries in the last two decades. But it has notably entered the government sector too, as regulators increasingly rely on analytical tools to uncover and prosecute violators.

With the UN’s Intergovernmental Panel on Climate Change (IPCC) sounding a “code red” alarm on the future of humanity, the topic of environmental, social and corporate governance (ESG) is more current than ever.

Data science has reshaped many industries in the last two decades. But it has notably entered the government sector too, as regulators increasingly rely on analytical tools to uncover and prosecute violators.

With the UN’s Intergovernmental Panel on Climate Change (IPCC) sounding a “code red” alarm on the future of humanity, the topic of environmental, social and corporate governance (ESG) is more current than ever.

Few fraud cases have garnered as much attention in the last decade as the Theranos scandal. The spectacular rise and fall of the biotech startup and its founder Elizabeth Holmes have already inspired a documentary and a best-selling book, while a Hollywood film starring Jennifer Lawrence is in the making. And now, as Holmes’ criminal fraud trial is underway, it looks like the Theranos saga might be drawing to an end.

Few fraud cases have garnered as much attention in the last decade as the Theranos scandal. The spectacular rise and fall of the biotech startup and its founder Elizabeth Holmes have already inspired a documentary and a best-selling book, while a Hollywood film starring Jennifer Lawrence is in the making. And now, as Holmes’ criminal fraud trial is underway, it looks like the Theranos saga might be drawing to an end.

What do Honeywell, Princeton University, and Keysight Technologies have in common? In the past year, all three entities have been found in violation of the US Export Administration Regulations (EAR). They could make it into the next edition of Don’t Let This Happen to You by the Bureau of Industry and Security (BIS).

What do Honeywell, Princeton University, and Keysight Technologies have in common? Find out in this article.

The US Commerce Department's Bureau of Industry and Security (BIS) released a final rule that added four foreign companies to the Entity List for engaging in activities contrary to the United States' national security or foreign policy interests

The US Commerce Department's Bureau of Industry and Security (BIS) released a final rule on November 3, 2021, that added four foreign companies to the Entity List for engaging in activities contrary to the United States' national security or foreign policy interests. One of the four named was NSO Group—the Israeli military-grade spyware manufacturer responsible for creating software traced to the phones of politicians, journalists, and human rights activists around the world.