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Tech Company Shares Tech, Makes Self-Disclosure, Pays Penalty

On February 19, 2014, the U.S. Commerce Department announced that it had reached an agreement with Santa Clara-based Intevac, Inc. to settle allegations that Intevac violated U.S. export regulations governing exports of...more

4/4/2014 - Export Administration Regulations Russia Technology Transfers Voluntary Disclosure

A Peek Around the Curtain: A False Claims Act Settlement for Avoiding Customs Charges

On November 14, 2013, the U.S. Department of Justice announced a False Claims Act settlement with Basco Manufacturing Company, a maker of shower enclosures, for $1.1 million related to misstatements on U.S. Customs and Border...more

1/9/2014 - Anti-Dumping Duty China Compliance Countervailing Duties Customs Customs and Border Protection DOJ False Claims Act Fees

Tryin’ to Make a Dollar out of Fifteen Cents: The Diebold FCPA Settlement Explains What Officials Did on Their Vacation

Vacation is great, but it can involve a great deal of planning. And, paradoxically, leisure travel can involve more planning than traveling for business. That travel-related work stands out as a centerpiece of the October...more

11/15/2013 - Bribery Deferred Prosecution Agreements Diebold Inc DOJ Enforcement Actions FCPA SEC

The European Court of Justice Overturns, Unfreezes EU Iran Sanctions

In a series of recent rulings, the European Court of Justice overturned economic sanctions issued by the Council of the European Union (EU) on several Iranian banks and shipping lines. On September 6 and 16, 2013, the Court...more

10/10/2013 - Banks ECJ EU Iran Sanctions Middle East Shipping

Still Standing: U.S. Court Upholds SEC Conflicts Minerals Rule

In a July 23, 2013 opinion, the U.S. District Court for the District of Columbia upheld the SEC’s rule requiring disclosure of companies’ use of conflict minerals originating in and around the Democratic Republic of the Congo...more

8/8/2013 - Africa Conflicts of Interest Dodd-Frank FCPA Minerals SEC

A Rising Voice on FCPA Compliance: The Court

One FCPA compliance topic we are often asked about by clients is how government investigations start. The U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have developed a number of mechanisms...more

6/11/2013 - Compliance DOJ FCPA IBM Investigations SEC

No Knowledge, but Hints of Omissions in the Allianz FCPA Settlement

On December 17, 2012, the Securities and Exchange Commission (“SEC”) announced a settlement under the U.S. Foreign Corrupt Practices Act (“FCPA”) with Allianz SE (“Allianz”), the insurance company based in Germany, resulting...more

1/10/2013 - Allianz Books & Records Bribery Compliance Disgorgement FCPA FCPA Resource Guide Penalties SEC

What’s Not in the New FCPA Resource Guide, or Why Doing Your FCPA Homework is Still a Good Idea

Notwithstanding our overall approval of the FCPA Resource Guide (the Guide) issued by the Department of Justice (DOJ) and Securities & Exchange Commission (SEC) earlier this month, we are certainly not above a bit of...more

12/6/2012 - Compliance DOJ FCPA FCPA Resource Guide SEC

ITAR End-Use Investigations Reveal Compliance Priorities

As many exporters know, the U.S. government conducts investigations under the so-called “Blue Lantern” program to monitor end-use compliance in defense trade exports. On October 23, 2012, the U.S. Department of State,...more

11/20/2012

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