Bribery

Lessons from Ralph Lauren: Designing Better Ways to Manage Third Party Risk

by NAVEX Global on 5/21/2013

Trying to avoid the unusually strict import controls in Argentina and facilitate faster clearance of its products through customs, a subsidiary of Ralph Lauren Corp. was found to have bribed local officials between 2005 and...more

PEMEX Files Suit to Recover $160 Million in Bribery Case

by Marta Colomar, Carlos Gonzalez | Michael Diaz Jr. - Diaz Reus International... on 5/20/2013

Mexican state oil company Pemex has filed a lawsuit in New York seeking to recover nearly $160 million from Germany's Siemens and South Korea's SK Engineering & Construction Co. Ltd. in a global bribery case, a law firm...more

International Bribery Charges Against Broker-Dealer Employees Result From SEC Exam

by BuckleySandler LLP on 5/14/2013

On May 7, the DOJ charged two employees of a U.S. broker-dealer and a senior official in Venezuela’s state economic development bank for their alleged roles in what the DOJ describes as a “massive international bribery...more

Unprecedented FCPA Wake-Up Call for U.S. Broker-Dealers and Foreign Banks: Has the Perfect FCPA Storm Finally Arrived for U.S....

by John Goselin, Mauro Wolfe | Duane Morris LLP on 5/14/2013

On May 7, 2013, the U.S. Attorney's Office for the Southern District of New York (SDNY) unsealed extraordinary criminal charges against two registered representatives of a U.S. broker-dealer and a high-level Venezuelan...more

Canada To Strengthen Its Laws Against Bribery Of Foreign Public Officials

by Alan Monk | Dentons on 5/13/2013

Mining and exploration companies with projects in developing nations should take note that an amendment to the Corruption of Foreign Public Officials Act (CFPOA) has been approved by the Senate and is currently before the...more

In FCPA Enforcement Sometimes Truth Is Stranger Than Fiction – The Cilnis Complaint

by Thomas Fox on 5/13/2013

I often marvel at some of the stories which come up in the context of Foreign Corrupt Practices Act (FCPA) investigations and enforcement. If you made up some of the things which are reported, I fear that people might find...more

Infobytes - A Weekly In-depth review of news & developments in the financial services industry - May 10, 2013

by BuckleySandler LLP on 5/13/2013

In This Issue: - FEDERAL ISSUES - STATE ISSUES - COURTS - MISCELLANY - FIRM NEWS - FIRM PUBLICATIONS - MORTGAGES - BANKING - CONSUMER FINANCE - SECURITIES - PRIVACY/DATA SECURITY -...more

Global Connection - May 2013: DOJ Investigation of a Media Company Shows that FCPA Is Best Viewed Broadly; Sting Operations Will...

by Sara J. Agne | Snell & Wilmer L.L.P. on 5/8/2013

The news this month that the FBI will continue to use sting operations to net Foreign Corrupt Practices Act (FCPA or the Act) violators only serves to emphasize that the FCPA is best viewed broadly. The net cast by the...more

FCPA Prosecutions Against Individuals? Check Out April

by Thomas Fox on 4/30/2013

One of the oft-heard criticisms of the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) is the lack of individual prosecutions under the Foreign Corrupt Practices Act (FCPA). That may well be on its...more

SDNY Imposes Second Highest Penalty Under Foreign Corrupt Practices Act

by Tenley Mochizuki, Emily Stern | Katten Muchin Rosenman LLP on 4/30/2013

The US District Court for the Southern District of New York recently ordered Uriel Sharef, a former Siemens AG board member and German citizen accused of bribing Argentine government officials, to pay a $275,000 civil penalty...more

Hospital And Physician Compliance With Anti-Kickback And Stark Restrictions

by Michael Volkov on 4/24/2013

A bribe is a bribe. It is not as easy as it sounds. Not all payments of money or transfers of value are bribes. The FCPA tells us that. It is even more complicated when trying to navigate Anti-Kickback and Stark law...more

Using Bribery And Corruption To Steal Business – A Thyestean Feast?

by Thomas Fox on 4/24/2013

Not much beats the ancient Greek House of Atreus for dramatic gore: infanticide, patricide, fratricide, filicide, matricide, cannibalism, incest and about every other horror which can befall one family occurs in the various...more

Ralph Lauren Escapes FCPA Problems with Minimized Damage

by David Smyth | Brooks Pierce on 4/23/2013

Often, enforcement officials at the SEC and the Justice Department express their wish that securities law violators own up to their (mis)conduct as soon it comes to light. That is, come to the government and explain what has...more

The Danger Of FCPA “Proactive” Investigations

by Michael Volkov on 4/22/2013

The old adage – if something is too good to be true, it probably is not – applies with equal force in the world of bribery and intrigue. The recent arrest of the mining executive for obstruction of the Justice Department’s...more

Distribution in China – Legal Issues

by John Huang, Frank Schoneveld, Winston Zhao | McDermott Will & Emery on 4/4/2013

McDermott Will & Emery is pleased to offer “Distribution in China – Legal Issues*,” a one-stop resource covering distribution in China, including: The business models and legal structures most commonly used for...more

Employee Jailed For Accepting Bribe

by Adrian Miedema | Dentons on 3/20/2013

An employee of a drive test centre has been jailed for accepting a bribe from a driving instructor, who has also been jailed....more

Suzanne Rich Folsom and Bart M. Schwartz on Corporate Compliance in 2011 [Video]

by LEVICK on 3/6/2013

As part of a continuing series of LEVICK video interviews with thought leaders across multiple disciplines and industry sectors, I recently sat down with Suzanne Rich Folsom, the former Vice President, Chief Regulatory and...more

When Counting Bribes For Sentencing Guidelines Purposes, You Only Count The Ones That Actually Happened

by Matthew G. Kaiser | The Kaiser Law Firm PLLC on 3/5/2013

Michael Roussel used to be a Captain in the New Orleans Police Department. As you might expect, he was convicted of bribery....more

New York Federal Court Holds SEC’s FCPA Enforcement Theory “Far Too Attenuated” For Jurisdiction

by BuckleySandler LLP on 3/1/2013

On February 19, the U.S. District Court for the Southern District of New York held that the SEC’s allegations of personal jurisdiction over a former CEO of Siemens’ Argentinian subsidiary – a German citizen with no direct...more

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

China’s Renewed Focus on Anti-Corruption Efforts Highlighted by a New Interpretation on Criminal Offense of Paying Bribes

by Timothy Blakely, Calvin Jin, Daniel Levison, Sherry Yin | Morrison & Foerster LLP on 2/27/2013

In the three months since the Communist Party of China (the “CPC”) convened its 18th National Congress in November 2012, the CPC’s new leaders, including newly appointed CPC General Secretary and China’s incoming president Xi...more

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Lessons from Ralph Lauren: Designing Better Ways to Manage Third Party Risk

PEMEX Files Suit to Recover $160 Million in Bribery Case

International Bribery Charges Against Broker-Dealer Employees Result From SEC Exam

Unprecedented FCPA Wake-Up Call for U.S. Broker-Dealers and Foreign Banks: Has the Perfect FCPA Storm Finally Arrived for U.S....

Canada To Strengthen Its Laws Against Bribery Of Foreign Public Officials

In FCPA Enforcement Sometimes Truth Is Stranger Than Fiction – The Cilnis Complaint

Infobytes - A Weekly In-depth review of news & developments in the financial services industry - May 10, 2013

Global Connection - May 2013: DOJ Investigation of a Media Company Shows that FCPA Is Best Viewed Broadly; Sting Operations Will...

FCPA Prosecutions Against Individuals? Check Out April

SDNY Imposes Second Highest Penalty Under Foreign Corrupt Practices Act

Hospital And Physician Compliance With Anti-Kickback And Stark Restrictions

Using Bribery And Corruption To Steal Business – A Thyestean Feast?

Ralph Lauren Escapes FCPA Problems with Minimized Damage

The Danger Of FCPA “Proactive” Investigations

Distribution in China – Legal Issues

Employee Jailed For Accepting Bribe

Suzanne Rich Folsom and Bart M. Schwartz on Corporate Compliance in 2011 [Video]

When Counting Bribes For Sentencing Guidelines Purposes, You Only Count The Ones That Actually Happened

New York Federal Court Holds SEC’s FCPA Enforcement Theory “Far Too Attenuated” For Jurisdiction

Limiting The FCPA’s Reach — Squaring Two Recent Decisions

China’s Renewed Focus on Anti-Corruption Efforts Highlighted by a New Interpretation on Criminal Offense of Paying Bribes

What Enforcement Actions Based On Distributor Conduct Teach About Improving FCPA Compliance Programs

Southern District of New York Ruling May Present Challenges for FCPA Defendants

Two Recent Decisions Provide Rare Guidance on the FCPA’s Reach Over Foreign Nationals

SDNY Favors the SEC in Foreign Corrupt Practices Act Action Involving Novel Issues of Statutory Interpretation

Suzanne Rich Folsom and Bart M. Schwartz on Corporate Compliance in 2011 [Video]

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