Commodity trader and producer Glencore has entered guilty pleas for conspiracy to violate the FCPA and conspiracy to commit commodity price manipulation and agreed to pay more than $1.1 billion to resolve charges relating to what the DOJ has called “staggering” bribery. The settlement, coordinated with the CFTC and the SFO, also requires the CEO and the head of compliance of the Switzerland-based company to personally certify to the DOJ that the company has met its compliance obligations at the end of the monitoring period, following through on Assistant Attorney General Kenneth Polite, Jr.’s announcement of that policy in March. The resolution, which also may be an indicator of how far the CFTC will reach as it ventures into corruption, might leave some wondering whether Glencore actually can make meaningful change given its seemingly widespread problems. See “Lessons from Telecom Giant Ericsson’s Billion-Dollar Record-Setting Deal
” (Jan. 8, 2020).