Private Equity and the FCPA

more+
less-

In a Wall Street Journal (WSJ) article on December 22, 2010 by Joe Palazzolo, he reported that the Securities and Exchange Commission (SEC) is investigating Europe’s largest insurer, Allianz SE, for possible bribery by a German printing press company in which it holds majority stake. Palazzolo opined that this probe could break new ground in US enforcement of the Foreign Corrupt Practices Act (FCPA). The SEC has never charged a private equity firm based on the conduct of a foreign private company in its portfolio. As we enter 2011, one of the things that the FCPA compliance community has learned from the prior year is that the Department of Justice (DOJ) and SEC have announced they will review the conduct of certain industries to determine if they are in compliance with the FCPA. In late 2009, the DOJ made a very public display of announcing it had targeted the pharmaceutical industry and in January, 2010, they arrested 21 individuals in the US armament industry in the largest ever FCPA undercover sting operation, the Gun Sting investigation.

LOADING PDF: If there are any problems, click here to download the file.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Thomas Fox, Compliance Evangelist | Attorney Advertising

Written by:

more+
less-

Compliance Evangelist on:

JD Supra Readers' Choice 2016 Awards
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×
Loading...
×
×