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Books & Records Bribery Internal Controls

Porter Hedges LLP

ComEd Settlement Proves the Foreign Corrupt Practices Act Is Not Limited to Foreign Corruption

Porter Hedges LLP on

On September 28, 2023, the Securities and Exchange Commission (“SEC”) announced that it reached a settlement with Exelon Corporation and its subsidiary, Commonwealth Edison Company (“ComEd”), relating to charges that ComEd...more

Bradley Arant Boult Cummings LLP

Philips Agrees to Pay $62M to Settle FCPA Books-and-Records Violations from Efforts to Win Chinese Contracts

Koninklijke Philips N.V., a global medical technology manufacturer, recently agreed to pay over $62 million to resolve a Foreign Corrupt Practices Act (FCPA) enforcement action with the Securities and Exchange Commission...more

The Volkov Law Group

Oracle’s FCPA Violations: A Lesson in Managing Third-Party Distributor Risks (Part II of II)

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Oracle’s SEC settlement for $23 million underscores the power of the FCPA provisions mandating effective internal controls and accurate books and records.  As everyone knows, these provisions can be applied to a wide-range of...more

The Volkov Law Group

KT Corp. Settles SEC FCPA Case for $6.3 Million (Part I of III)

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The SEC announced its first FCPA enforcement action in 2022. South Korean telecommunications company, KT Corporation, agreed to pay $6.3 million to settle FCPA violations.  As part of the settlement, KT Corp. agreed to pay...more

The Volkov Law Group

WPP, the Largest Global Advertising Group, Settles FCPA Charges with SEC for $19.2 Million (Part I of III)

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After a long hiatus, the SEC announced a settlement with WPP plc, the world’s largest advertising group, for FCPA violations in India, China, Brazil and Peru for $19.2 million.  The SEC’s resolution charges WPP with...more

The Volkov Law Group

DOJ Hits Beam Suntory with FCPA Settlement for $19.5 Million (Part I of II)

The Volkov Law Group on

Beam Suntory, a global producer and distributor of distilled beverages, settled its FCPA case with DOJ for $19.5 million for bribes paid in India.  The DOJ settlement follows an SEC FCPA settlement for $8 million announced...more

The Volkov Law Group

World Acceptance Corporation Settles FCPA Charges with the SEC for $21.7 Million

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World Acceptance Corporation (“WAC”), a US-based consumer loan company, agreed to pay the SEC $21.7 million for FCPA violations in Mexico.  WAC’s cited violations covered the full gamut of FCPA violations, including bribery...more

Thomas Fox - Compliance Evangelist

Recidivist Eni: Corruption, Controls and Books and Records

Eni S.p.A (Eni) joined the two-time Foreign Corrupt Practices Act (FCPA) loser ranks last week when it agreed to a Cease and Desist Order (Order) with the Securities and Exchange Commission (SEC) for violations of the...more

Foodman CPAs & Advisors

Instituciones Financieras y el FCPA

La Ley de Prácticas Corruptas en el Extranjero (“Foreign Corrupt Practices Act – FCPA”) prohíbe el pago de sobornos a funcionarios extranjeros para ayudar a obtener o retener negocios.  Exige que las empresas cuyos valores se...more

Foodman CPAs & Advisors

Financial Institutions and the FCPA

The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business.  It requires companies whose securities are listed in the US to maintain books and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Ericsson Agrees To Pay Over USD $1 Billion To Settle FCPA Charges

On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 5: Lessons Learned for the Compliance Professional

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 3: Internal Control Failures

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

The Volkov Law Group

Episode 119 -- The Ericsson FCPA Settlement

The Volkov Law Group on

The Sweden-based telecommunications company, Ericsson, agreed to a pay a total of $1 billion (yes, billion with a “B”) for FCPA violations. Ericsson entered into settlement agreements with DOJ and the SEC. Ericsson agreed to...more

Bass, Berry & Sims PLC

(Another) Big Bank Pays FCPA Penalty for Hiring Practice

Bass, Berry & Sims PLC on

• A payment to a government official can take many forms. • The SEC charges bank for books and records violation even absent a bribery charge. • Industry-wide enforcement is a continuing tactic for U.S. regulators. ...more

Thomas Fox - Compliance Evangelist

Two Tickets to Paradise and the Thiruvengadam FCPA Settlement

We got a fair bit more clarity on the Cognizant Technologies Solutions Corporation (“Cognizant”) Foreign Corrupt Practices Act (FCPA) last week, when Sridhar Thiruvengadam, the Chief Operating Officer (COO) agreed to settle...more

Dorsey & Whitney LLP

Second Circuit: Supreme Court’s McDonald Decision Does Not Delimit FCPA

Dorsey & Whitney LLP on

The bribery provisions of Exchange Act Section 30A are one of the three critical components of the Foreign Corrupt Practices Act. The other two are the books and records and the internal control requirements....more

Wilson Sonsini Goodrich & Rosati

Telefônica Brasil Case Reinforces Risks of Gifts and Hospitality Involving Foreign Officials

On May 9, 2019, Telefônica Brasil agreed to pay a US$4.13 million civil fine to settle U.S. Securities and Exchange Commission charges for violations of the internal accounting controls and recordkeeping provisions of the...more

Troutman Pepper

Enhanced Anti-Corruption Scrutiny in Construction Industry

Troutman Pepper on

Bribery and corruption have long plagued the construction industry, particularly in emerging markets in Latin America, Eastern Europe, the Middle East and Asia-Pacific. ...more

A&O Shearman

Telecommunications Provider & Subsidiary Enter Into Settlement, Deferred Prosecution Agreement And Plea Agreement With SEC And DOJ...

A&O Shearman on

On March 6, 2019, the Securities and Exchange Commission (“SEC”) announced that it was settling allegations that Russian telecommunications company Mobile Telesystems Pjsc (“MTS”) violated anti-bribery, books and records, and...more

Holland & Knight LLP

Petrobras Agrees to Pay More Than $1.8 Billion for Facilitating FCPA Violations

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• Four years ago, Brazilian authorities began Operation Car Wash, a wide-ranging and still ongoing corruption and money laundering investigation that has spanned 11 countries. • The fallout continues with a recent U.S....more

Thomas Fox - Compliance Evangelist

Stryker FCPA Enforcement Action: Compliance Lessons For Distributors and Dealers – Part II

Over this two-part blog post series, I have been considering the Stryker Corporation 2018 Foreign Corrupt Practices Act (FCPA) enforcement action brought by the Securities and Exchange Commission (SEC)....more

The Volkov Law Group

Sanofi Coughs Up $25 Million to Settle SEC FCPA Charges

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Well, add another pharmaceutical company to the FCPA healthcare “sweep.” Frankly, the term “sweep” makes it sound like a coordinated enforcement effort – instead, it is more accurate to think of it as multiple prosecutions...more

The Volkov Law Group

Legg Mason Pays $34 Million to Resolve SEC’s Libyan FCPA Investigation

The Volkov Law Group on

Legg Mason can finally close its books on the Gaddafi-era, Libyan bribery scandal. In June 2018, Legg Mason entered into a non-prosecution agreement with the Justice Department and agreed to pay $32 million for its role in...more

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