Bribery, DOJ | JD Supra Law News

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

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

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

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

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

by Thomas Fox on 2/27/2013

Ed. Note-today we have a guest post by our colleague, William C. Athanas, a partner in the law firm of Waller Lansden Dortch & Davis, LLP. In the prior two posts, David Simon and myself posited different approaches to...more

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

by William H. Devaney, Geoffrey Garinther, Nancy Grunberg, Jan Lawrence Handzlik, Hillary Profita | Venable LLP on 2/27/2013

A recent ruling in the Southern District of New York rejected two defenses in a Foreign Corrupt Practices Act (FCPA) case, resulting in an interpretation of the law that could have damaging consequences for defendants who are...more

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

by Ropes & Gray LLP on 2/27/2013

Two recent district court decisions have shed light on the reach and scope of the U.S. Foreign Corrupt Practices Act (FCPA) over foreign nationals: SEC v. Straub and SEC v. Sharef. For companies and individuals operating...more

Increased Risk of FCPA Prosecution of Foreign National Executives of U.S. Issuers: Recent Court Decision Allows Open-Ended Statute...

by Anthony D. Mirenda, Gare Smith | Foley Hoag LLP on 2/19/2013

A recent federal court decision highlights the increasing risk of prosecution for foreign national executives under the Foreign Corrupt Practices Act ("FCPA”). The decision from the federal district court in New York denied...more

Doing Business In Italy - Step Up Your FCPA Compliance Now

by Thomas Fox on 2/18/2013

Former Italian Prime Minister Silvio Berlusconi is no stranger to scandal and controversial statements, but lately his words and actions seem to be providing cause for concern outside of the European Union....more

New FCPA Decision: How Long is the FCPA’s Reach?

by Paul T. Friedman, Adam Hunt, Ruti Smithline | Morrison & Foerster LLP on 2/15/2013

A little more than a year after Deustche Telekom (“DT”) and Magyar Telekom entered into multi-million dollar settlements with the SEC and DOJ to resolve claims that the two companies violated the FCPA, three former Magyar...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

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

Failing To Act: Lessons From 2012 FCPA Enforcement

by Michael Volkov on 2/12/2013

FCPA practitioners tend to repeat themselves. Some of the points we make need to be repeated, and some do not. Businesses are not able to react as quickly as they should in response to potential risks and possible...more

Amnesty for Armstrong? Lessons for the Compliance Practitioner

by Thomas Fox on 2/1/2013

The Lance Armstrong saga continues to provide many lessons for the compliance practitioner. A recent article on ESPN.com, entitled “Lance calls for amnesty program”, reported that Armstrong has come out in favor of those who...more

Transaction Monitoring Under the FCPA [Video]

by Thomas Fox on 1/31/2013

Transaction monitoring was mentioned in a couple of significant enforcement actions of 2012. I think that it will move to becoming a best practice in FCPA compliance programs. This video will explain how transaction...more

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Bribery › Dept. of Justice

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

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

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

Ralph Lauren Escapes FCPA Problems with Minimized Damage

The Danger Of FCPA “Proactive” Investigations

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

Increased Risk of FCPA Prosecution of Foreign National Executives of U.S. Issuers: Recent Court Decision Allows Open-Ended Statute...

Doing Business In Italy - Step Up Your FCPA Compliance Now

New FCPA Decision: How Long is the FCPA’s Reach?

Distributors under the FCPA

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

Failing To Act: Lessons From 2012 FCPA Enforcement

Amnesty for Armstrong? Lessons for the Compliance Practitioner

Transaction Monitoring Under the FCPA [Video]

Glengarry Glen Ross and the Internal Marketing of a Compliance Program

Rolls-Royce Brings in Lord Gold – Is it Thinking Big Enough?

Fu Manchu and the Wal-Mart FCPA Investigation Water Torture

Five Biggest FCPA Stories Of 2012

Highlights of the Government's New FCPA Resource Guide

Transaction Monitoring Under the FCPA [Video]

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