The
recent rise
of deferred prosecution agreements, as a hallmark
of SFO case resolution (which may or may not involve
allegations of money laundering), means that there are no prosecutions
of the companies which may have received criminal proceeds.
The practice's
recent representations include: (i) CONMEBOL in connection with U.S. criminal investigations and prosecutions into
allegations of bribery and corruption in the international soccer world; (ii) the Special Committee
of Banco BTG Pactual S.A. («BTG Pactual») in an internal investigation
of alleged corruption involving its former CEO and other bank executives, in which we found no basis to support the
allegations against the Bank and its employees; (iii) two
of the largest construction companies in Brazil in potential civil and criminal investigations and litigation involving the Petrobras bribery scandal (Lava Jato), the largest corruption scandal in Latin American history, involving
allegations of over $ 2.5 billion in bribes and kickbacks; (iv) the Government
of Brazil in a corruption matter involving former senior government officials and multiple jurisdictions; (v) the General Manager
of one
of the largest energy companies in Central America in connection with
allegations of bribery in Guatemala; (vi) a Mexican high - ranking executive for Wal - Mart Stores, Inc. in connection with DOJ and SEC FCPA investigations against Wal - Mart; (vii) a large Argentinean oil company and its owner, one
of Argentina's wealthiest individuals, in connection with high - profile DOJ and SEC investigations involving alleged FCPA violations to secure an extension
of oil rights in an Argentinean oilfield; (viii) the United State's largest chemical and industrial products companies in an internal investigation
of alleged corruption involving its Mexican subsidiary; (ix) the Rosenthal family, one
of the most prominent families in Central America, in a number
of related criminal matters; and (x) a senior executive
of one
of Venezuela's largest engineering companies in DOJ investigations into corruption and
money laundering involving PdVSA.