Kodiak Gas Services is a provider of natural gas contract compression services.
In late 2023, Kodiak announced its intent to acquire CSI Compressco LP whose customers included various business in several foreign countries including Mexico, Canada, Argentina, and Chile.
This previous post highlighted a 2025 disclosure by Kodiak regarding compliance issues in Mexico.
Kodiak’s most recent
FCPA Professor LLC
Described as “the Wall Street Journal concerning all things FCPA-related,” and "the most authoritative source for those seeking to understand and apply the FCPA," FCPA Professor has been named a Top Law Blog for in-house counsel by Corporate Counsel, a Top 25 Business Law Blog by LexisNexis, and a top 100 Legal Blog by the American Bar Association. FCPA Professor readers include a world-wide audience of attorneys, business and compliance professionals, government agencies, scholars and students, journalists and other interested persons.
Website:
http://fcpaprofessor.com/
An Interesting Take
By Mike Koehler
Law firm client alerts on Foreign Corrupt Practices Act topics are usually rather basic – the so-called “who, what, where” regarding the development.
Which makes this recent Morrison & Foerster alert which addressed the recent dismissal in U.S. v. Rovirosa a bit unusual.
First, some background.
In December 2025, Ramon Alexandro Rovirosa Martinez was found…
FCPA Scrutiny Of Methode Electronics Ends
By Mike Koehler
Methode Electronics, Inc., a publicly traded company based in Chicago, is “a leading global supplier of custom-engineered solutions with sales, engineering and manufacturing locations in North America, Europe, Middle East, and Asia.”
The Company’s solutions are found in the end markets of transportation (including automotive, commercial vehicle, e-bike, aerospace, bus and rail), cloud computing…
SEC Rescinds Long-Standing Settlement Policy
By Mike Koehler
The SEC’s long-standing “neither admit nor deny” settlement policy has been the focus of posts on this site for approximately 15 years.
Yesterday, the SEC rescinded the policy.
The SEC release states:
“The Securities and Exchange Commission today rescinded a policy, codified in Rule 202.5(e) of its informal rules of procedures, stating that when it…
Checking In On the Adani Enforcement Actions
By Mike Koehler
In late 2024, the SEC and DOJ brought enforcement actions against various individuals associated with Adani Group and Azure Power in connection with an alleged Indian bribery scheme.
Both the SEC and DOJ enforcement actions included a Foreign Corrupt Practices Act component (see here and here), but not as to Gautam Adani (a citizen of…
New Director Of The SEC’s Division Of Enforcement Speaks
By Mike Koehler
David Woodcock (the new Director of the SEC’s Division of Enforcement) recently delivered this speech.
Woodcock stated that his goals are “to return the enforcement program back to basics” with an “emphasis on quality over quantity.”
Whether Woodcock’s speech was relevant to the Foreign Corrupt Practices Act (part of the securities laws after all)…
Fugitive FCPA Defendant Seeks A Pardon
By Mike Koehler
In 2018, the DOJ announced that Low Taek Jho (Jho Low – pictured), Ng Chong Hwa (Roger Ng – a former managing director at Goldman Sachs), and Tim Leissner (the former Southeast Asia Chairman at Goldman Sachs and Participating Manager Director) were charged with FCPA offenses for paying bribes to various Malaysian and…
Top Ten FCPA Settlements
By Mike Koehler
Set forth below is the current top ten corporate FCPA settlements of all-time actually secured by U.S. law enforcement (in other words net FCPA settlement amounts).
Unlike certain other lists, the below list is calculated after consistently accounting for certain credits or deductions in several enforcement actions involving foreign companies and/or related foreign law enforcement…
DOJ Files Notice Of Appeal Regarding Rovirosa Dismissal
By Mike Koehler
“Broken Windows Securities Enforcement”
By Mike Koehler
At a recent conference, SEC Commissioner Mark Uyeda offered remarks on the “effectiveness of the broken windows policy in the securities enforcement context.”
As Uyeda explained, “the broken windows hypothesis, as described in a seminal article published in The Atlantic by James Q. Wilson and George Kelling, posits that visible signs of disorder, when left…