You can always count on the FCPA paparazzi. When things are quiet in the FCPA world, they will take a mountain and turn it into a molehill. They have nothing better to write about; they have nothing better to focus on then...more
Ed. Note-David Simon is a partner at Foley and Lardner and Bill Athanas is a partner at Waller Lansden Dortch & Davis, LLP. Both have practices which include FCPA compliance. After my recent post on distributors under the...more
In This Issue: - FCPA Due Diligence is Critical to Avoid Successor Liability in Cross-Border Transactions - China’s Merger Control Rules...more
If there was ever a question that distributors were covered under the Foreign Corrupt Practices Act (FCPA), in 2012, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) made it emphatically clear that...more
When Judge Sporkin, the father of the FCPA, assisted Senator William Proxmire in the drafting of the FCPA, he advised Senator Proxmire that a “books and records” provision was all that was needed to address the problem of...more
On December 17, 2012, the Securities and Exchange Commission (“SEC”) announced a settlement under the U.S. Foreign Corrupt Practices Act (“FCPA”) with Allianz SE (“Allianz”), the insurance company based in Germany, resulting...more
On December 17th, the SEC brought a settled administrative FCPA action against Allianz SE, a German insurance company with a subsidiary in Indonesia. The order does not allege violations of the FCPA’s antibribery provisions,...more
On December 17, 2012, the Securities and Exchange Commission ("SEC") announced that Allianz SE ("Allianz"), a German-based insurance and asset management company, had agreed to pay approximately $12.3 million to settle...more
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