In This Issue:
¦¦ Recent FCPA developments
¦¦ The UK Bribery Act
¦¦ China’s new anti-corruption law
¦¦ Extraterritorial cross-over
¦¦ Corruption in developing markets in context
¦¦ Collective action
Managing liability risks under anti-corruption laws can be a daunting prospect for most corporations, but this task is particularly complicated for multinational corporations with operations in developing economies where history, culture and customs impact day-to-day business. Several notable enforcement and legislative developments in recent months highlight this continuing challenge for multinational corporations.
- In early May, Avon Products Inc. fired four executives over bribes to Chinese officials according to a regulatory filing. The four individuals, who were initially suspended in April 2010 during an internal investigation, included a general manager and former head of finance of the company’s China unit. As part of its internal probe, Avon has reportedly discovered millions of dollars in questionable payments in India, Japan, Argentina, Brazil and Mexico. In February of this year, the company conceded that it could face substantial fines, civil and criminal penalties and other sanctions, depending on how the Foreign Corrupt Practices Act (FCPA) matter is resolved. The investigation is reportedly ongoing.
- Citigroup faces lengthy bans on its credit card and wealth management businesses in Indonesia over a case of alleged embezzlement and the death of a client following questioning by debt collectors. Citigroup has said it is working closely with Indonesia’s central bank to address its concerns.
These two examples are representative of the risks faced by corporations and the importance of compliance efforts to avoid liability under applicable anti-corruption laws...
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