O Golpe – Brics, Dólar e Petróleo Euclides_Mance_O_Golpe_Brics_Dolar_e_Petroleo | Page 363

NOTAS E CITAÇÕES NOS IDIOMAS ORIGINAIS
put on three conferences dedicated to the training of foreign prosecutors on investi-
gations, best practices around anti-corruption compliance program and cooperation
between countries in sharing of documents and other evidence.”
19
“FUTURE TRAINING: […] there is a continual need to provide hands-on
training to Brazilian federal and state judges, prosecutors, and law enforcement re-
garding the illicit financing of criminal conduct. [...] Ideally, the training should be
longer-term and coincide with the formation of training task forces. Two large ur-
ban centers with proven judicial support for illicit financing cases, in particular Sao
Paulo, Campo Grande, or Curitiba, should be selected as the location for this type
of training. Then task forces can be formed, and an actual investigation used as the
basis for training that would sequentially progress from investigation through the
courtroom presentation and conclusion of the case.”
20
“conference on Illicit Finance Oct 4-9 (reftel), held in the regional capital of
Rio de Janeiro and funded by State,s Coordinator for Counter Terrorism (S/CT). This
is the first regional conference conducted under post,s Projeto PONTES (Transla-
tion: Bridges Project) umbrella, a new training concept post introduced in February
2009 to consolidate bi-lateral law enforcement training.”
21
“the primary mission of the Office of the Coordinator for Counterterrorism
(S/CT) is to forge partnerships with non-state actors, multilateral organizations, and
foreign governments to advance the counterterrorism objectives and national secu-
rity of the United States.”
22
“According to IBP’s Pradal, likely PSDB 2010 Presidential Candidate Jose Ser-
ra opposed the framework, but seemed to lack a sense of urgency on the issue. She
quoted him as telling industry representatives, “Let those guys [Worker’s Party] do
what they want. There will be no bid rounds, and then we will show everyone that the
old model worked...And we will change it back.”
23
the FBI’s International Corruption Unit and a special squad at the Bureau’s
Washington Field Office is combatting foreign corrupt practices
24
“No matter what the reason, when foreign officials receive bribes, they threat-
en our national security and the international free market system in which we trade
[…]. Just because they’re out of our sight, doesn’t mean they’re beyond our reach. The
FBI will use all available resources to put an end to this type of corrupt behavior.”
25
“Investigators say that anti-money laundering (AML) violations often point
to illicit bribe and fraud schemes. The Brazil case shows how a local AML case led to
a hierarchy of corruption in the country so vast they might not have been able to go
ahead without the involvement of global enforcement agencies.”
26
“The first quarter of 2018 saw a flurry of declinations of FCPA prosecutions
by the DOJ and the SEC, and only one FCPA corporate enforcement resolution by
the DOJ and two resolutions by the SEC. This activity—or lack thereof—appears
consistent with senior DOJ officials’ statements that, absent corporate misconduct
that is “serious or pervasive enough” to warrant an entity-level criminal resolution,
the DOJ wants “to avoid imposing penalties that disproportionately punish innocent
employees, shareholders, customers, and other stakeholders” […] // “Based on pub-
licly available records, FCPA charges were brought against only one individual in the
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