INTERNATIONAL CORRUPTION. Federal Bureau of Investigation Proactive Global Strategy SA MICHAEL SOLARI
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1 INTERNATIONAL CORRUPTION Federal Bureau of Investigation Proactive Global Strategy SA MICHAEL SOLARI
2 DISCLAIMER The FBI, as a matter of policy, disclaims responsibility for any private publication or statements by any of its employees. The views expressed herein are those of the presenter and do not necessarily reflect the views of the FBI or the presenter s colleagues.
3 FBI PRIORITIES 1. Protect the United States from terrorist attack 2. Protect the United States against foreign intelligence operations and espionage 3. Protect the United States against cyber-based attacks and hightechnology crimes 4. Combat Public Corruption at All Levels 5. Protect civil rights 6. Combat transnational/national criminal organizations and enterprises 7. Combat major white-collar crime 8. Combat significant violent crime 9. Support federal, state, local and international partners 10. Upgrade technology to successfully perform the FBI's mission 3
4 CORRUPTION A BILLIONAIRES PERSPECTIVE WHY NOT INVEST? Too Dirty Too Dangerous TOO CORRUPT My Money can clean My Money can secure But My Money will only feed the corruption.
5 CORRUPTION IS LIKE A COCKROACH It is Always There Hiding in Shadows Lurking in the Corners of the Room It is nurtured by Tolerance
6 WITHOUT ENFORCEMENT IT MULTIPLIES Do you want to do business here?
7 COST OF CORRUPTION Rule of Law Epidemics Corruption Economic Growth Security Terrorism U.S. NATIONAL SECURITY Stability Human Rights Violations
8 FBI INTERNATIONAL CORRUPTION UNIT ICU Programs Foreign Corrupt Practices Act Priority International Money Laundering Threat (PIMLAT) /Kleptocracy 8
9 FOREIGN CORRUPT PRACTICES ACT OF 1977 Commonly referred to as the FCPA. Statute - Title 15, U.S.C. 78-dd-1, et seq. Prohibits bribe payments to foreign officials. Initially only applied to U.S. companies. 9
10 EXPANSION OF LEGISLATION 1998, FCPA expanded to include foreign companies under certain circumstances: Companies traded on U.S. stock exchange. Transactions which use a U.S. bank (essentially, any transaction in U.S. dollars). Transactions which involve any act in furtherance of such a corrupt payment while in the U.S. 10
11 FCPA ANTI-BRIBERY PROVISIONS Prohibits U.S. and certain foreign companies from: Paying or promising to pay anything of value; To foreign officials, For the purposes of: influencing any official act or decision; or inducing the official to take any action or refrain from taking any action in violation of his/her lawful duty; obtaining any improper advantage; or inducing the official to influence or affect any act of a government; In order to assist the company in obtaining or retaining business or directing business to any person. 11
12 FCPA ACCOUNTING PROVISIONS The Books and Records Provisions: Public companies must make and keep books, records and accounts which accurately and fairly reflect the transactions and dispositions of the assets of the issuer Books must accurately reflect that the payment is a bribe Public companies must devise and maintain a system of internal accounting controls that provide reasonable assurances that the transactions are properly authorized Devise and maintain an effective systems of internal controls to detect or prevent violations of the FCPA, including due diligence on resellers, consultants, and training for employees 12
13 DEFINITIONS: A THING OF VALUE Any commercial good or service provided to a government official. To include Indirect benefits can also be a thing of value. 13
14 DEFINITION: FOREIGN OFFICIAL The following are considered Foreign Officials: Officers or employees of any foreign government and any department, agency, ministry or subdivision thereof; State-owned entities and their employees; Public international organizations; and Any person acting in an official capacity on behalf of any of the foregoing. Foreign Officials cannot be prosecuted under the FCPA. 14
15 DEFINITION: OBTAINING OR RETAINING BUSINESS Obtaining or retaining business : Payments made for specific contracts; Payments that may indirectly relate to obtaining business. Reducing tax obligations Re-zoning Immigration Beneficial audit Special Licensing 15
16 FCPA COMPANION STATUTES Mail/Wire Fraud (Title 18, U.S.C. 1341, 1343) Maximum 20 years sentence Travel Act (Title 18, U.S.C. 1952) Maximum 5 year sentence Money Laundering (Title 18, U.S.C. 1956, 1957) Maximum 20 years sentence State Commercial Bribery Statutes Conspiracy Statute (Title 18, U.S.C. 371) 16
17 WHEN INTERNAL CONTROLS AND PROCEDURES ARE NOT ENOUGH Enforcement Consequences Costs Reputation Share value Additional Expenses Freedom
18 KEYS TO FBI INTERNATIONAL SUCCESS Work with local authorities and regulators. Strengthen existing relationships while expanding to other partners. Embedded Agents in Europe, Asia, Africa, S. America. Intelligence Sharing. Continue to foster relationships with business and industry.
19 FBI LEGATS FBI international presence consists of our Legal Attaché offices, located in over 70 key cities worldwide, providing coverage to more than 200 countries, territories, and islands. 19
20 INTERNATIONAL COOPERATION Makes US investigations overseas more effective. Gives investigators and prosecutors better access to witnesses, documents, and evidence; removes many hurdles faced in international investigations. Reciprocal benefits to foreign governments and foreign law enforcement. Facilitates prosecutions in multiple countries. More countries now have laws making bribery illegal. Many countries have joined against corruption and are assisting international investigations and prosecutions. We ve come a long way. 10 years ago bribe payments were still a tax deductible expense in many European countries. 20
21 FBI COMMITMENT TO THE FUTURE Dedicate more resources to target international violations. This July Special Agents were added around the globe to address these issues. Special Investigative Units compiled in 7 locations in the U.S. to include DC, New York and Los Angeles
22 THANK YOU Special Agent Michael Solari
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