Books & Records, SEC | JD Supra Law News

Limiting The FCPA’s Reach — Squaring Two Recent Decisions

by Michael Volkov on 2/28/2013

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

Distributors Should Be Analyzed As Any Other Third Party Representative in the Sales Chain

by Thomas Fox on 2/25/2013

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

Inside M&A - Winter 2013

by Obiamaka P. Madubuko, Jeffrey Rothschild, Frank Schoneveld, Jake Townsend | McDermott Will & Emery on 2/22/2013

In This Issue: - FCPA Due Diligence is Critical to Avoid Successor Liability in Cross-Border Transactions - China’s Merger Control Rules...more

Distributors under the FCPA

by Thomas Fox on 2/13/2013

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

SEC Staff Seeking Hard Drives, Etc. (but without authority)

by David Smyth | Brooks Pierce on 2/12/2013

Last month brought us this story from Reuters, in which we learned that the SEC “has become more aggressive in seeking full hard drives from the companies and individuals it investigates, startling defense lawyers who...more

The HP Acquisition of Autonomy – Lessons Learned for Doing Compliance ‘By the Book’

by Thomas Fox on 2/12/2013

Doing something ‘by the book’ means more than following a process. It means following that process during high stress times. One of the things that I think gets missed when discussing compliance programs is the need for rigor...more

Significant Amendments Proposed to Strengthen Canada’s Anti-Corruption Regime

by Thomas Fox on 2/7/2013

Ed. Note-this week there was a-buzz from North of the Border where it was announced that Canada was considering amendments to strengthen the Canadian anti-corruption law, the Corruptions of Public Officials Act. I ask John...more

The FCPA Guidance And Accounting Controls

by Michael Volkov on 2/5/2013

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

No Knowledge, but Hints of Omissions in the Allianz FCPA Settlement

by Mark Jensen, Matthew Riemer | Sheppard Mullin Richter & Hampton LLP on 1/10/2013

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

SEC Charges Allianz with FCPA Violations

by David Smyth | Brooks Pierce on 1/2/2013

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

Allianz To Pay $12.3M To Settle SEC’s Bribery Allegations

by Raymond Banoun | Cadwalader, Wickersham & Taft LLP on 12/20/2012

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

SEC’s Asset Management Unit Focuses on Compliance Failures, Vol. 2

by David Smyth | Brooks Pierce on 12/19/2012

As we discussed last month, the SEC’s Asset Management Unit has developed a likeness for not just big, headline-grabbing cases, but relatively small compliance-based cases that are designed to prevent minor problems from...more

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Books & Records › Securities & Exchange Commission