Question

With respect to the FCPA materials, please submit a response that

identifies the Department of Justice FCPA enforcement action you've read about by date and by Docket No (for example, Docket No: 14-CR-240-DLC)

identifies the charged parties

briefly summarizes the issues involved (NOTE: this information will be most easily obtained from the press release that the Department of Justice released in connection with the indictment) and

briefly states whether you think the party against whom the enforcement action has been taken was treated appropriately (assuming the facts cited are correct).

Answer 1

The issues involved in UNITED STATES V. BENITO CHINEA COURT DOCKET NUMBER: 14-CR-240-DLC

• The defendants used to work in
• The defendants were involved in a bribery scheme in which the defendants paid bribes to a third person Maria Gonzalez, who in turn brought business from Bandes to the Broker-Dealer.
• A portion generated of the deal was kick-backed to Gonzalez by the defendants using unauthorized means
• This unauthorized activity was concealed by defendants so as not to come in anyone’s notice
• On enquiry, the defendants were found guilty under FCPA, a anti-corruption based law
• The defendants even used to circulate spreadsheets to keep a track of the personal gains of the people involved in this fraud activity.
• The defendants were trialed and sentenced for executing this international bribery

In my views, the defendants had got equal representation in the case. The court had produced the spreadsheets, which were used to keep track of the individual gains made by the defendants in this bribery scheme. The defendants were definitely guilty under FCPA and Travel Act, and therefore, deserved the sentence.