FCPA Compliance and Ethics Report-Episode 94-Internal Controls for Gifts, Travel and Entertainment in a FCPA Compliance Program, Part II
FCPA Compliance and Ethics Report-Episode 53-Gifts, Travel and Entertainment Under the FCPA
If one were to reflect upon the providing of gifts and business entertainment to foreign governmental officials, one might reasonably conclude that after 40 years of the FCPA, companies might follow its prescriptions...more
Ed. Note-Jim McGrath was a great friend and a trusted colleague who passed away in 2014. As a tribute to McGrath and each year for Christmas, I submit for your enjoyment, the below post which originally appeared on McGrath’s...more
This year, India celebrates Diwali on October 19, 2017. “The Festival of Lights,” as Diwali (or Deepavli) is commonly called, is celebrated across India with great aplomb, joy and, of course, delicious sweets. Diwali...more
FLIR Systems, Inc. (“FLIR”), a publicly traded company based in Oregon, agreed to pay approximately $9.5 million to settle allegations of violations of the Foreign Corrupt Practices Act (“FCPA”) on April 8, 2015. The U.S....more
Life can be very humbling. The SEC has definitely humbled me. For years now, I have been claiming that companies spend too much time worrying about gifts, meals and entertainment expenses under the FCPA, rather than...more
Now that we have reviewed all of the public record pronouncements from the Department of Justice (DOJ) and Securities and Exchange Commission (SEC), this post will try and suggest what you might need in your Foreign Corrupt...more
Last week the SEC reported that Diebold, Inc. agreed to pay more than $48 million in fines and prejudgment interest to settle SEC civil charges and DOJ criminal charges that it had violated the Foreign Corrupt Practices Act....more
The Greek ruler Draco has received some very bad PR advice over the centuries. ...more
It is time for everyone to take a deep breath. The DOJ/SEC Guidance could not have been clearer. The message to companies – stop devoting so much time to building, tinkering with, and monitoring their policies governing...more