Episode 276 -- Review of Phillips and Franks Int'l SEC FCPA Settlements
The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination. But even a declination comes with a requirement — the company has...more
Recent disruptions in the global food supply chains have highlighted Africa's urgent need to become self-sufficient in food production. Traditionally, the continent has turned to small-scale community-based agricultural...more
The SEC recently announced two separate FCPA SEC enforcement actions -- the first against Franks International for $8 million for FCPA violations in Angola; and the second against Philips, a Dutch medical device company, for...more
Franks International (“Frank’s”) settled FCPA charges with the SEC for $8 million stemming from operations in Angola during the period 2008 to 2014. The Justice Department declined to prosecute Frank’s for the same events....more
On November 18, 2022, the European Commission announced the conclusion of negotiations between the European Union (EU) and the Republic of Angola on a Sustainable Investment Facilitation Agreement (SIFA)....more
One key facet of the Angolan government's recent reforms is the Privatization Framework Law (Law No. 10/19, enacted in May 2019 and approved by Presidential Decree no. 250/19 in August 2019). This Decree will govern Angola's...more
The current impact of privatization on the development and diversification of Angola's infrastructure. One of Africa's trade heavyweights, Angola is blessed with a wide range of natural resources and a fertile climate. It...more
In today’s blog post, I want to look at some of the more unusual bribery schemes from Foreign Corrupt Practices Act (FCPA) enforcement actions in 2019. Some of these schemes were not unusual but they were accomplished with...more
Along with the anti-bribery provisions, the U.S. Foreign Corrupt Practices Act (“FCPA”) contains accounting provisions that apply to publicly traded companies. These provisions require that companies maintain and adhere to...more
Last week’s announcement by the Securities and Exchange Commission (SEC) of the resolution of its outstanding Foreign Corrupt Practices Act (FCPA) enforcement action with Halliburton Company continues to resonate and provide...more
June Foray died this week. You may not think you have heard of her but let me assure you; you have heard her. Foray was the voice of Rocket J. Squirrel in perhaps the greatest cartoon show ever, Rocky and Bullwinkle....more
After years of fits and starts, and promises and disappointments, the Serious Fraud Office and the UK Bribery Act made its initial splash on the anti-corruption enforcement landscape. Since 2011, companies have been...more
Today I conclude my series on the Rolls-Royce global anti-corruption enforcement action by taking a look what it all means going forward. The resolution is more than simply the stunning fines and penalties of £671 million...more
On 17 January 2017, the UK Serious Fraud Office (“SFO”),[1] the US Department of Justice (“DOJ”),[2] and the Brazilian Ministério Público Federal (“MPF”) announced an $800 million global settlement with Rolls-Royce plc and...more
Today I continue my exploration of the Rolls-Royce global corruption enforcement action by considering the company’s resolution in the US under the Foreign Corrupt Practices Act (FCPA). Before we dive into that, I first...more
When most people across the globe think of Rolls-Royce, one word comes to mind – excellence. Yet that image largely relates to Rolls-Royce Limited, the automobile manufacturer, which was founded in 1909. Just a few years...more
The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) continued their stunning run of 2016 Foreign Corrupt Practices Act (FCPA) enforcement actions right up to the end of the year with the announcement...more
You know this has been a big year in FCPA enforcement when DOJ and the SEC announce two FCPA settlements during the usually sleepy week between Christmas and New Years. And what a year it has been – more to follow in my...more
Leading the News - Nigeria: On December 1st, the United Nations (U.N.) reported nearly 450 schools have reopened in Borno state, Nigeria since October after being closed for more than 18 months following the Boko...more
Despite a decline in enforcement actions by the Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the...more
FERC Shares Best Practices for Stakeholder Outreach in Gas Project Permitting - The dramatic increase in domestic energy production over the past several years has resulted in the involvement of the Federal Energy...more
On 11 August 2015, Angola's New Private Investment Law ("NPIL") came into force on its publication in Angola's Gazette, repealing the previous 2011 law. Like its predecessor, the NPIL sets out the rules applicable to...more