Bribery Securities & Exchange Commission

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Dorsey Anti-Corruption Digest - April 2016

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more

Las Vegas Sands $9 Million SEC Settlement: An Easy Mark

The SEC continues its cutting edge FCPA enforcement program, bringing in a variety of enforcement cases and employing some new strategies. In its latest foray, the SEC settled with Las Vegas Sands, owned by Sheldon...more

DOJ’s Fraud Section Issues Foreign Corrupt Practices Act Enforcement Plan and Guidance

On April 5, 2016, the Department of Justice’s Fraud Section (“DOJ”) issued its Foreign Corrupt Practices Act (“FCPA”) Enforcement Plan and Guidance (“Guidance”), which announced (1) a more than doubling of DOJ resources...more

Are Your Company’s Legal, Due-Diligence, De-risking, or Compliance Obligations Impacted by the “Panama Papers”?

In an unprecedented event earlier this week, 11.5 million files from the Panamanian law firm Mossack Fonseca were allegedly leaked. Assuming they are genuine, as appears to be the case, these “Panama Papers” offer a...more

Avoiding the “Al Capone” version of an FCPA enforcement action—Are your internal controls in order?

Notorious gangster Al Capone likely was guilty of numerous crimes, including bootlegging, maintaining a house of prostitution, bribery, racketeering and multiple counts of murder. Yet he was never convicted of those crimes. ...more

FinCrimes Update - March 2016 Summary, Volume 4, Issue 3

BREAKING NEWS: PANAMA PAPERS: IMPLICATIONS FOR FINANCIAL CRIMES COMPLIANCE PROFESSIONALS - A group of international news outlets published a series of articles this week regarding the so-called “Panama Papers;” 11.5...more

Historic FCPA Settlement Reflects Increased Regulatory Focus on International Anticorruption Issues Arising from M&A Transactions

Most employers already know that violating the Foreign Corrupt Practices Act of 1977 (FCPA) has serious consequences, including significant fines. Those potential fines just got even heavier. On February 18, 2016, the U.S....more

Novartis Coughs Up $25 Million to SEC for China FCPA Violations

Last week, the SEC announced another FCPA settlement involving the pharmaceutical industry for bribery in China. The SEC’s settlement filing represents yet another example of the pharmaceutical industry run amok in China,...more

FinCrimes Update - February 2016 Summary, Volume 4, Issue 2

OCC AND FINCEN ASSESS CIVIL MONEY PENALTIES AGAINST FLORIDA-BASED WEALTH MANAGEMENT FIRM FOR BSA VIOLATIONS - On February 25, the OCC, in coordination with FinCEN, announced that it took action against a Florida-based...more

A Lesson in Compliance: Part II

The following is an interview with Richard Bistrong and Alessia Lamonaca, Program Marketing Specialist at Resolver Inc. In “A Lesson in Compliance with Richard Bistrong: Part I“, Richard discussed the thought process...more

SEC Settles with Health Science Company and Former Employee Over Bribes to Russian Government Officials

On March 3, the SEC announced it settled FCPA charges with a health science company and a former engineer, Mikhail Gourevitch, for their role in bribing Russian government officials to obtain approvals for a liver cancer...more

Drug and Medical Device Corruption Risks in China

Medical device and pharmaceutical companies know the risks of conducting business in China. Company after company has had to settle FCPA enforcement actions in China. Many of these enforcement actions include fact patterns...more

Massachusetts-Based Technology Company and Two Chinese Subsidiaries Pay $28 Million to Settle Civil and Criminal FCPA Charges; SEC...

On February 16, the SEC and DOJ announced a settlement with a Massachusetts-based technology company for violations of the FCPA. The technology company and two Chinese subsidiaries agreed to pay $28 million to settle the...more

Amsterdam-Based Telecommunications Company Pays $795 Million to Settle FCPA Charges Both in US and Abroad

On February 18, an Amsterdam-based telecommunications company and its Uzbek subsidiary reached a global settlement with the SEC, DOJ, and Dutch regulators Openbarr Ministerie (OM) and the Fiscal Intelligence and Investigation...more

PTC Inc. and No Cooperation Credit Case Under Yates

On February 16, 2016, the Securities and Exchange Commission (SEC) and the Department of Justice (DOJ) announced parallel resolutions with PTC Inc, (formerly Parametric Technology Corporation), a Massachusetts based software...more

VimpelCom's Global FCPA Settlement - A Multinational Resolution

The U.S. Department of Justice (DOJ), the U.S. Securities and Exchange Commission (SEC) and the Public Prosecution Service of the Netherlands (OM) announced a coordinated criminal and civil Foreign Corrupt Practices Act...more

Key Takeaways From This Year’s Early FCPA Enforcement Actions

February has been a big month for U.S. Foreign Corrupt Practices Act (FCPA) enforcement. It started with the U.S. Securities and Exchange Commission (SEC) quietly resolving a string of relatively small matters. Then, at the...more

VimpelCom Final Thoughts

Today, I conclude my exploration of the VimpelCom Foreign Corrupt Practices Act (FCPA) enforcement action. As I said yesterday, this case will be studied for some time as a textbook example of bribery schemes used...more

PTC Settlement: Compliance Reminders for Internal Controls, Travel and Gifts

PTC, a Massachusetts software company, reached settlements with the SEC and DOJ last week for FCPA violations for a total of $28 million. Interestingly, the SEC announced a DPA with a PTC official who assisted in the...more

A 'Very Different Picture': Landmark FCPA Corporate Settlement After Relatively Slow 2015 Enforcement

When asked about the relatively slow year of Foreign Corrupt Practices Act (“FCPA”) prosecutions in 2015, the Chief of the DOJ Criminal Division’s Fraud Section suggested last month: “one year isn’t long enough to tell the...more

The Carrot and the Stick: The SEC’s First Deferred Prosecution Agreement with an Individual in an FCPA Case

In a move that highlights both the increased focus on holding individuals accountable and the credit that can be earned through cooperation, the U.S. Securities and Exchange Commission (“SEC”) announced last week that, for...more

VimpelCom Settles FCPA Case – Part I

In what can only be termed a stunning resolution, last week the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) announced a resolution of a long-standing Foreign Corrupt Practices Act (FCPA) probe...more

Return of the Jedi (DOJ): The Vimpelcom Enforcement Action (Part I of II)

Welcome back to the Department of Justice and FCPA enforcement. After a lengthy hiatus, DOJ returned to the FCPA enforcement scene with a demonstration of its full capability, assuming certain individuals are prosecuted...more

More FCPA Grief Involving Gifts, Travel & Entertainment: PTC in China – Part III

I have been exploring the PTC Inc. Foreign Corrupt Practices Act (FCPA) settlement this week. It included a Non-Prosecution Agreement (NPA) from the Department of Justice (DOJ) with two Chinese subsidiaries and a Cease and...more

This Week In Securities Litigation

The Commission filed two settled FCPA cases this week. On was resolved with the payment of almost $800 million to the SEC, DOJ and Dutch regulators where about $114 million in bribes were paid. The other centered on the...more

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