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FCPA Today: A timeline of the Unaoil bribery investigation

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The Lead

March 2016

  • The Huffington Post/Fairfax Media reports Monaco-based Unaoil paid bribes on behalf of oil and gas companies including Rolls-Royce, Weatherford, Saipem, SBM Offshore, ABB, Petrofac, and others.
  • Monaco police raid the Unaoil offices.
  • The UK Serious Fraud Office (SFO) opens an investigation into Unaoil, but doesn't make a public announcement.

May 2016

  • KBR and FMC Technologies say the Justice Department contacted them with questions about Unaoil. Both said they are cooperating.

June 2016

  • Unaoil says it will take legal action against Fairfax Media and its partners, and file a criminal complaint with law enforcement in Monaco for the theft of company data.

July 2016

  • SFO announces it's conducting a criminal investigation into Unaoil, its officers, employees, and agents in connection with suspected offenses of bribery, corruption, and money laundering.
  • SFO says it's flush with sources coming forward with information.


The Big Picture

The DOJ filed forfeiture complaints seeking $1 billion against assets, including mansions, art, and private jets, allegedly bought with money looted from Malaysia's sovereign wealth fund, 1Malaysia Development Berhad.

Mexico signed into law its new National Anti-Corruption System, though some aren't happy as the so-called "3-of-3" (personal assets, tax information, and economic interests) disclosures for public officials aren't mandatory.

"Who wants to spend three hours getting depressed about governance?" That's how the creator and guide of the newly introduced Chicago Corruption Walking Tour starts the session.


The Blogs

Michael Volkov dives into the new AML and Sanctions Regulations by the New York Department of Financial Services. The new regulations go into effect on January 1, 2017.

Going down the rabbit hole, Martin Kenney tackles the psychology of fraud in a thoughtful essay.

Continuing his series on Johnson Controls, Tom Fox discusses its DOJ declination.

Andy Spalding talks about Brazil’s second "pillar" of its new anti-corruption initiative, the access to information law.

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