Corruption Bribery

News & Analysis as of

The Ping FCPA Enforcement Action: Lessons for the Compliance Practitioner

The Securities and Exchange Commission (SEC) settled a Foreign Corrupt Practices Act (FCPA) enforcement action against an individual earlier this month when it announced the resolution of a matter involving Jun Ping Zhang,...more

Three Key Takeaways from the Nu Skin FCPA Settlement for a Corrupt Charitable Donation

In a rare enforcement action, the SEC settled an FCPA enforcement action for $766,000 for a charitable donation of $154,000 to improperly influence a high-ranking Chiese Communist party official to prevent a provincial agency...more

DOJ Moves to Dismiss Public Corruption Charges Against Former VA Governor

Last week, the U.S. Attorney’s Office for the Eastern District of Virginia moved to dismiss public corruption charges against former Virginia Governor Robert McDonnell, and his wife, Maureen McDonnell. The decision comes...more

The Foreign Corrupt Practices Act’s One-Year “Pilot Program” Nears The Halfway Mark

The Foreign Corrupt Practices Act (“FCPA”) prohibits both United States and foreign corporations and nationals from offering or paying, or authorizing the offer or payment, of anything of value to a foreign government...more

When Diligence is Not Given its “Due”

I find myself quibbling with compliance terms – hyper focus on small issues is not a positive trait. I often urge clients and colleagues to focus on issue of more significance and leave the smaller ones for another day....more

For An Effective Ethics and Compliance Program — First, Train Your Board and Senior Executives

Compliance professionals are familiar with the phrase “tone at the top,” but what exactly does it mean? Unlike other compliance program components, it cannot be easily formalized and implemented in a policy or procedure....more

The Costs of Corruption

We always hear about the macroeconomic impact of corruption. Using large figures in the billions and even trillions (5 percent of global GDP) and painting catastrophic pictures of societal harm, anti-corruption advocates...more

Tribute to Star Trek and Anti-Corruption Compliance Programs

September 8th is the 50th anniversary of the premier episode of the most iconic science fiction related television show during my lifetime – Star Trek. As most of you know, I am a self-confessed uber-trekkie and I can still...more

Hallmark 10 – Mergers and Acquisitions: Pre-Acquisition Due Diligence and Post-Acquisition Integration

The FCPA Guidance notes that one of the ten hallmarks of an effective compliance program is around mergers and acquisitions (M&A), in both the pre and post-acquisition context. A company that does not perform adequate FCPA...more

FCPA Enforcement Actions and Reputational Damage

If you ask members of a corporate board or senior executives about the cost of an FCPA enforcement action, they will candidly acknowledge all of the costs – fines, penalties, and professional costs (e.g. legal, accounting,...more

Lessons from History and a Best Practices Compliance Program

I am on assignment in Oxford on a two-week study course, focusing on the Tudors. For the first week we focused on Richard III to the end of Henry VIII’s reign. Although Richard III was not a Tudor, we began with him to study...more

Five Key Takeaways from Key Energy’s SEC FCPA Settlement

The SEC, last week, announced its $5 million settlement with Key Energy. As always, FCPA settlements contain important examples of enforcement priorities and policies. Key Energy’s recent settlement is an example of the...more

Key Energy FCPA Resolution – Part III

This week I have been exploring the Key Energy, Inc. (Key Energy) Foreign Corrupt Practices Act (FCPA) enforcement action. Today, I want to consider the actions taken by Key Energy to obtain the very good resolution the...more

Farewell to R2D2 and Key Energy FCPA Resolution – Part II

Yesterday I began a what I thought would be a two-part series on the Key Energy, Inc. (Key Energy) Foreign Corrupt Practices Act (FCPA) enforcement action. However (and as usual), I got carried away so today I will review the...more

Farewell to John Saunders and Welcome to Key Energy FCPA Resolution – Part I

John Saunders died last week. He was a reporter at ESPN and the host of the Sunday talking heads show, the Sports Reporters. The tributes for Saunders came from far and wide. By all accounts, he was one of the most beloved...more

From Altamont to Airbus

What was one of the most tragic events in the history of rock and roll? High up on the list must rank the Altamont concert, held at Altamont Race Track on December 6, 1969. It was so bad that many people felt the 60s actually...more

FCPA Compliance: Does “Anything of Value” Really Mean “Anything of Value”?

The FCPA statute is not as vague as some contend. I remember the words of a former FTC Chairperson who told me once – “The Clayton Act is not vague. I just read the law and apply it to the facts.”...more

Headlines from Mid-Year FCPA Enforcement Review

Just to add my voice to the cottage industry surrounding FCPA enforcement and compliance, I wanted to take a deep breath and offer some observations on FCPA enforcement in 2016. There are a few significant headlines...more

DOJ and SEC Collect $22 Million from LAN Airlines for Conduct in Resolving Labor Dispute

Last week, the Justice Department and the SEC announced parallel FCPA settlements totaling $22 million in fines, penalties and disgorgement against LAN Airlines, a Chile-based airline, for conduct in resolving a labor dispute...more

Shareholders Will Get to Trial in Petrobras Corruption Scandal Action

Yesterday I wrote about what may well be the next great bribery and corruption scandal across the globe involving the Venezuelan state oil company Petroleos de Venezuela SA (PDVSA). However, the current largest corruption...more

SBM Offshore N.V. signs five party $340M leniency agreement to resolve Petrobras bribery allegations in Brazil

SBM Offshore N.V. has reached a $340M settlement with both criminal and administrative prosecutors in Brazil to resolve allegations of bribery relating to the Petrobras scandal, the first deal of its kind in Brazil and a...more

Red Flags Squelch Corrupt PDVSA Deal

As the Petrobras corruption scandal seems to be going strong, we turn our attention to what may be the most corrupt of all the national energy companies, the Venezuelan state oil company Petroleos de Venezuela SA (PDVSA)....more

LATAM/LAN FCPA Enforcement Action, Part I-Some Questions

What is the cost of a Foreign Corrupt Practices Act (FCPA) violation? One subset of that question is what is the cost of not cooperating and not remediating during the pendency of such investigations? Those were two of the...more

New Anti-Corruption Laws on the Health Care Sector in Germany: Is There Any Impact on the Food Industry?

Germany recently adopted new anti-corruption laws that now criminalize “taking bribes in the health care sector” and “giving bribes in the health care sector.” These new laws have implications for certain segments of the food...more

Farewell to Ralph Stanley and a Success in Repatriation

Yesterday I honored Scotty Moore, the lead guitarist for Elvis Presley, who died last week. Today I want to pay homage to another equally large giant from the world of music who recently died, Ralph Stanley. Stanley,...more

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