Compliance & Investigations

Recent matters DGKV’s Compliance team has worked on include:

• Advising a large portfolio of clients on AML matters and UBO disclosures.
• Successfully representing SE Bordnetze – Bulgaria EOOD in court proceedings aimed at establishing a variety of misrepresentations – including invoicing for fictitious transportation services – and recovering unduly paid amounts.
• Representing a Bulgarian telecom operator in a complex case involving a high-end white-collar-crime investigation related to the acquisition of its Bulgarian subsidiary. 
• Representing Paul Hartmann AG in a case of wire fraud that resulted in several bank transfers made into two Bulgarian bank accounts, including filing a complaint with the Bulgarian prosecution authorities that led to the instigation of pre-trial criminal proceedings.
• Representing Investint SA (part of Groupe ETAM) in a case of banking fraud involving a payment made by a Belgian company into a Bulgarian bank account held by a Bulgarian company, instead of paying the amount to a French counterparty for its services, including filing a request for an injunction freezing the bank account, and the subsequent initiation of an (ultimately successful) civil case for unjust enrichment against the account holder.
• Representing ASL Airlines Belgium SA in a case of banking fraud involving a EUR 1.9 million payment made to a Bulgarian bank account in the name of ASL Airlines Ireland Ltd. that had been fraudulently opened by an imposter.
• Successfully representing Corob S.p.A. in relation to an attempted fraud against one of its Saudi Arabian customers which resulted in a EUR 580,000 transfer to a “false” bank account opened in Bulgaria.
• Successfully representing Framo Netherland B.V. (a subsidiary of ALFA LAVAL) in a complicated financial fraud case in Bulgaria.
• Representing a Swedish individual in his attempt to recover a loan of EUR 100,000 he made to a Bulgarian company for the purpose of financing a film production.
• Representing one of the shareholders in a Canadian company in relation to suspected corporate malfeasance within the group, including advising the shareholder about possible remedies for alleged presentation of false information in certain IPO materials and misappropriation of funds and assets by certain group-management members.
• Successfully representing OMV Bulgaria OOD in an antitrust investigation launched by the CPC in April 2016 against six of the largest fuel retailers for alleged horizontal price fixing and price coordination.
• Advising Apple Inc. and its subsidiary Apple Distribution International Ltd in an investigation initiated by the Bulgarian Competition Protection Commission regarding an alleged abuse of superior bargaining position by Apple Inc. vis-a-vis the Bulgarian Telecommunication Company regarding the supply and distribution of smartphones in Bulgaria.
• Providing competition and regulatory-compliance advice to Axpo Group and its Bulgarian subsidiary, Axpo Bulgaria, including conducting  dawn-raid, competition, and market-manipulation trainings to the local team and assisting with ongoing investigations of the trade in natural gas conducted by Bulgarian law enforcement authorities.
• Advising Nikon Europe B.V. on an investigation launched by the CPC in January 2018 into an alleged abuse of dominant position and prohibited practices in vertical agreements with respect to the operation of the company’s selective distribution system in Bulgaria.
• Representing Aurubis Bulgaria AD in proceedings before the CPC related to an investigation of alleged horizontal price coordination and abuse of dominant position on the market of supply of sulphuric acid.
• Representing Kaliakra AD and two other Bunge group companies in an antitrust investigation of alleged vertical price fixing in distribution of vegetable oils.
• Assisting Zimmer GmbH, a global medical technology company, with the conduct of an internal FCPA and compliance investigation that focused on the operations of Bulgarian distributors and sales partners.