Alstom

News & Analysis as of

No Room for Companies to Gamble as the Feds Double Down on FCPA Enforcement

In 2014, a record-setting year for Foreign Corrupt Practices Act (FCPA) enforcement, the Department of Justice (DOJ) announced the largest-ever DOJ FCPA resolution—an over $772 million criminal fine for French power company...more

FCPA Compliance and Ethics Report-Episode 131, The FCPA Professor Takes a Look Back at 2014 [Video]

In this episode I visit with the FCPA Professor over some of his observations from the 2014 FCPA year just pass. We discuss the Esquenazi decision, Opinion Releases and several enforcement actions. ...more

January FCPA Enforcement Digest – FCPA Compliance Training Top Priority in 2015

With as much FCPA activity as we saw in December, I thought our January news digest might take on a different flavor. I was wrong – January brought a slew of new FCPA-related stories. ...more

FinCrimes Update - January 2015, Volumn 2, Issue 1

In This Issue: - BSA/AML & OFAC | FCPA & Anti-Corruption | Criminal Enforcement ...more

FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras [Video]

In this episode, Compliance Week Editor-in-Chief Matt Kelly and I discuss the Avon and Alstom FCPA enforcement actions and then take a look at the ongoing Petrobras corruption scandal and what it means for Brazil. ...more

Alstom Guilty Plea Sends Strong Message that DOJ Has Harsh View of Inadequate Internal Controls and Failure to Fully Cooperate

On December 22, 2014, French power and transportation company Alstom S.A. (“Alstom”) pleaded guilty to violating the Foreign Corrupt Practices Act (“FCPA”) and agreed to pay $772.29 million, the largest criminal fine ever...more

FCPA Compliance and Ethics Report-Episode 119-FCPA Year in Review, Part I [Video]

In this episode I begin a two-part review of the 2014 FCPA year. In this episode I review some of the significant corporate enforcement actions. ...more

The Alstom Case: Realities and Lessons Learned

The old expression goes – “Do not break your arm patting yourself on the back” – but maybe I might just extend my arm a little with the Alstom settlement. Last year I predicted that the Alstom case would eclipse Siemens as...more

Recent Trends and Patterns in Foreign Corrupt Practices Act (FCPA) Enforcement

In this memo: - Enforcement Actions and Strategies - Perennial Statutory Issues - Compliance Guidance - Unusual Developments - Private Litigation - Enforcement in the United...more

Top Ten International Anti-Corruption Developments for December 2014

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month with links to primary...more

December FCPA Enforcement Digest – Let’s Celebrate the New Year with Anti-Bribery Training!

Happy New Year! I hope everyone had a wonderful holiday and a great start to the New Year. With that said, I hope you’re not suffering from the holiday hangover (and I don’t mean the alcohol-induced kind.) After taking...more

FCPA Predictions for 2015 (Part II of II)

The key to being a successful (FCPA) prognosticator is never to keep score. If you do, you are likely to be disappointed. Instead, I follow the strategy of calculated distraction – for example, I predicted last year...more

Byzantium and the Alstom FCPA Settlement – Part III

Porphyry is a type of stone that was much favored in the Roman world. In a review of several books in the New York Review of Books, entitled “The Purple Stone of Emperors”, Peter Brown looked into the history of the lithic in...more

The FCPA Year in Review: Twist and Shout (Part I of II)

We all like annual reviews and predictions for the upcoming year – it is a New Year’s rite of passage and one that brings perspective and a sense of order to our otherwise chaotic lives....more

FCPA Compliance and Ethics Report-Episode 118-the Alstom FCPA Enforcement Action [Video]

In this episode 118, I take a deep dive into the Alstom FCPA enforcement action and its implication for the CCO and compliance practitioner. I also discuss comments from Dick Cassin and the FCPA Professor on the case. ...more

Germany in the World Cup and the Alstom FCPA Enforcement Action – Part II

“It was important that we played our game for 90 minutes.” That line was found in a The Daily Telegraph article entitled “The unthinkable scoreline: Brazil 1, Germany 7” by Jeremy Wilson. It was a quote from Mats Hummels,...more

This Week In Securities Litigation (Holiday wrap-up edition)

Through the holidays (Dec. 19 – 31, 2014) the Department of Justice and the SEC continued to file securities enforcement actions. The Department brought an FCPA case which is now number two on the top ten list for amounts...more

Pow! Whack! Slam! Bam! – DOJ Finishes the FCPA Year with a Bang

Giving away my old age, we all loved the 1960s Batman series starring Adam West. Thanks to the Batman show we were given a long list of words to underscore Batman and Robin’s slugfests with the weekly villain (e.g. Penguin,...more

The Alstom FCPA Enforcement Action – Part I

As the first blog post of 2015, I thought it appropriate to highlight two outstanding confluences. The first is that this year is the centenary of the birth of Orson Welles. While not occurring in 2015, near the end of 2014...more

Alstom’s FCPA Guilty Plea and Fine of $772 Million Offer Compelling Lessons

The December 23, 2014, announcement by the U.S. Department of Justice (DOJ) that Alstom, S.A., a French power and transportation company, pled guilty to two Foreign Corrupt Practices Act (FCPA) charges and agreed to pay $772...more

Alstom to Pay Largest FCPA Criminal Penalty in History

Earlier this week, Alstom S.A., a French multinational power and transportation company, pleaded guilty in the District of Connecticut to a two-count information charging it with violating the accounting provisions of the...more

Alstom Joins Santa’s Naughty List – In a Very Big Way

The North Pole for Foreign Corrupt Practices Act (FCPA) enforcement action announcements seems to have temporarily moved south for the month of December. Last week there was the final announcement of the long-standing Avon...more

FCPA Compliance and Ethics Report-Episode 115-Tom Fox and Matt Kelly on COSO, Bruker Corp, Dallas Airmotive and Alstom [Video]

In this episode Compliance Week editor Matt Kelly and I discuss the COSO 2013 Framework implementation and its changes from the prior Framework. We also discuss the recent Bruker Corp & Dallas Airmotive FCPA enforcement...more

Resurgence of Protectionism – Can European Member States Really Do Whatever They Want to Foreign Takeovers?

EU Competition Commissioner Joaquín Almunia recently cited the French initiatives to block the GE-Alstom deal as an example of “worrying signals of protectionist threats” in Europe. France is not, however, to be singled out....more

Marubeni: FCPA Repeat Offender

In this era of aggressive FCPA enforcement, there are critics who have suggested that the Department of Justice should concentrate its prosecutions on individuals rather than imposing ever-increasing criminal fines on...more

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