Message from @Disseminating truth
Discord ID: 495106241140490242
https://www.justice.gov/opa/pr/petr-leo-brasileiro-sa-petrobras-agrees-pay-more-850-million-fcpa-violations
Department of Justice
Office of Public Affairs
FOR IMMEDIATE RELEASE
Thursday, September 27, 2018
Petróleo Brasileiro S.A. – Petrobras Agrees to Pay More Than $850 Million for FCPA Violations
Reaches Agreement with Brazilian Authorities in Related Investigation
Petróleo Brasileiro S.A. – Petrobras (Petrobras), a Brazilian state-owned and state-controlled energy company, entered into agreements with U.S. and Brazilian authorities and agreed to pay a combined total of $853.2 million in penalties to resolve the U.S. government’s investigation into violations of the Foreign Corrupt Practices Act (FCPA) in connection with Petrobras’s role in facilitating payments to politicians and political parties in Brazil, as well as a related Brazilian investigation.
Assistant Attorney General Brian A. Benczkowski of the Justice Department’s Criminal Division, U.S. Attorney G. Zachary Terwilliger of the Eastern District of Virginia and Assistant Director Robert Johnson of the FBI’s Criminal Investigative Division made the announcement.
https://www.justice.gov/opa/speech/deputy-assistant-attorney-general-matthew-s-miner-justice-department-s-criminal-division
For those who may be scratching their heads, I’m referring to what was until very recently called the United States Attorney’s Manual or USAM.
The name change may take a little getting used to, but given that the policies in the Manual are applicable to all Department employees, not just Assistant U.S. Attorneys, I think the name change is appropriate.
As Deputy Attorney General Rod Rosenstein stated when announcing the FCPA policy change: “The new policy enables the Department to efficiently identify and punish criminal conduct, and it provides guidance and greater certainty for companies struggling with the question of whether to make voluntary disclosures of wrongdoing.”
Given my experience in private practice, I know firsthand the difficult decisions that management must make when they uncover misconduct.
Senior management, boards of directors and their advisors have to weigh many factors when deciding how to respond to misconduct.
But of all the decisions that need to be made, whether to voluntary self-disclose is perhaps one of the most difficult.
The goal of the FCPA Corporate Enforcement Policy is to encourage voluntary self-disclosures by making clear the benefits for companies that voluntarily self-disclose, fully cooperate and remediate, most significantly a presumption of a declination. It also spells out the Department’s expectations for companies to satisfy the standards in the policy.
https://www.justice.gov/opa/pr/department-justice-announces-rollout-updated-united-states-attorneys-manual
“This was truly a Department-wide effort, involving hundreds of employees collaborating from many different Department components,” said Deputy Attorney General Rod Rosenstein. “To mark this significant undertaking, and to emphasize that the Manual applies beyond the United States Attorneys’ Offices, we have renamed it the Justice Manual. Though the name has changed, the Manual will continue as a valuable means of improving efficiency, promoting consistency, and ensuring that applicable Department policies remain readily available to all employees as they carry out the Department’s vital mission.”
You have gained a rank @Disseminating truth, you just advanced to 9 . Thanks for all you do Patriot!
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