Morrison Foerster is an international law firm with lawyers practicing throughout the United States, Asia, and Europe. Click to discover more.

mofo_share_image.jpg

Morrison Foerster

favicon.ico

favicon-16x16.png

favicon-32x32.png

apple-touch-icon.png

MoFo Favicons

Terms / Notices

Cookies

Privacy Policy

Attorney Advertising

Secure Login

Alumni

  Facebook

MoFo Facebook

  Linkedin

MoFo LinkedIN

Twitter

MoFo Twitter

YouTube

MoFo Youtube

Morrison Foerster - Footer

You have not solved the recaptcha challenge yet or session expired, try again.

Disclaimer

Unsolicited e-mails and information sent to Morrison & Foerster will not be considered confidential, may be disclosed to others pursuant to our <a href="https://www.mofo.com/about/privacy-policy.html">Privacy Policy</a>, may not receive a response, and do not create an attorney-client relationship with Morrison & Foerster. If you are not already a client of Morrison & Foerster, do not include any confidential information in this message. Also, please note that our attorneys do not seek to practice law in any jurisdiction in which they are not properly authorized to do so.

Feedback

mofo-logo-2022.svg

People

Capabilities

Resources

About

Culture

Offices

Careers

Stay Connected

James Koukios spoke to Anti-Corruption Report about Luxembourg-based steel pipe manufacturer Tenaris agreeing to pay the Securities and Exchange Commission (SEC) more than $78 million to resolve charges related to its Brazilian subsidiary paying bribes to a Brazilian government official between 2008 and 2013, though the U.S. Department of Justice (DOJ) has indicated that it does not intend to pursue its own charges.



$78 Million SEC Resolution, But No DOJ Prosecution for Tenaris Despite Recidivism

About Morrison Forester

people-default-header-desktop.jpg

people-default-header-mobile.jpg

Default Meta Data

James Koukios spoke to Anti-Corruption Report about Luxembourg-based steel pipe manufacturer Tenaris agreeing to pay the Securities and Exchange Commission (SEC) more than $78 million to resolve charges related to its Brazilian subsidiary paying bribes to a Brazilian government official between 2008 and 2013, though the U.S. Department of Justice (DOJ) has indicated that it does not intend to pursue its own charges.The DOJ declining to prosecute is supported by the inclusion of a civil penalty in the SEC order, but DOJ did not send the company a Corporate Enforcement Policy (CEP) declination letter. “The lack of a CEP declination letter suggests that DOJ declined due to a lack of evidence or the existence of a compelling defense, as opposed to a policy-based declination,” James said.He added: “Although the SEC stated that Tenaris had failed to implement adequate internal accounting controls in the wake of the 2011 resolution, a good portion of the underlying conduct took place before the original resolution was reached and appears to have stopped in or around 2013. That gave Tenaris many years to enhance its compliance program and remediate issues before the resolution.”Read the <a target="_blank" href="https://www.anti-corruption.com/19259756/and3678million-sec-resolution-but-no-doj-prosecution-for-tenaris-despite-recidivism.thtml">full article</a> (subscription required).

$78 Million SEC Resolution, But No DOJ Prosecution for Tenaris Despite Recidivism

Sign Up

James M. Koukios

Partner

FCPA + Global Anti-Corruption