FCPA Compliance and Ethics Report-Episode 109-interview with Bill Michael on the SEC FCPA enforcement action against FLIR employees
FCPA Compliance and Ethics Report-Episode 107 the Bio-Rad FCPA Enforcement
FCPA Compliance and Ethics Report-Episode 105-interview with Barry Vitou
Anti-Corruption Due Diligence Practical Steps to Protect Your Company from Third Party Risks
Creating an Integrated Due Diligence System - Screening to Audits
Third Party Due Diligence When is Enough, Enough?
An FCPA Review: A Look Back at 2013 and Trends for 2014
How Can You Better Protect Yourself with the Escalating Trend of FCPA Enforcement?
AML BSA and Sanctions Compliance Part II of II June 24, 2014
Thomson Reuters Session - April: Investment Management, Hedge Funds & Registered Mutual Funds: What's Happening Now?
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
Building an Integrated Third Party Due Diligence System Initial Screening to Audits
Fine Tuning Your Anti Corruption Compliance Program
FCPA Compliance and Ethics Report-Episode 21 Update on Current Enforcement Actions, Investigations and Settlement Negotiations
Trends in FCPA Compliance and Enforcement for 2014
FCPA Compliance and Ethics Report-Episode 14 with the FCPA Professor
The New Normal: Taking Responsibility for Your Vendors
Lessons Learned from the BizJet Executives FCPA Enforcement Actions
Transaction Monitoring Under the FCPA
One hundred and 13 years ago on this date, the first Nobel Prizes were awarded in Stockholm, Sweden, in the fields of physics, chemistry, medicine, literature, and peace. The ceremony came on the fifth anniversary of the...more
Improper Gifts Alone, Without Cash Bribes, Serve as Basis for SEC’s Latest FCPA Enforcement Action -
Earlier this week, the SEC announced fines for two former defense contractor employees for FCPA violations relating...more
The Fourth Quarter of 2014 has been a busy one for DOJ and SEC in the FCPA arena. We are all praying that DOJ and SEC resolve the Avon case soon so that we do not have to include the case on our lists for predictions for...more
The SEC filed another settled FCPA action. The proceeding named two individuals as Respondents. It centers on using expensive gifts and travel as bribes. In the Matter of Stephen Timms, Adm. Proc. File No. 3-16281 (November...more
The SEC and the DOJ resolved FCPA charges with California based life science research and clinical diagnostics company Bio-Rad Laboratories, Inc. The charges stem from bribes paid in Russia, Vietnam and Thailand. The company...more
Layne Christensen, a global water management, construction and drilling company resolved FCPA bribery and books and records and internal controls charges with the SEC. In the Matter of Layne Christensen Company, Adm. Proc....more
Last Friday, China’s 15-month-long bribery investigation into British multinational pharmaceutical GlaksoSmithKline (GSK) ended after a one-day trial in which the court found GSK’s local subsidiary guilty of bribing doctors...more
The illicit or foreign payments cases -
The preliminary inquiry was followed by formal SEC investigations early in 1974. The resulting cases would become known as the “illicit or foreign payments” cases. The focus of...more
One of the more confusing areas of the US Foreign Corrupt Practices Act (FCPA) is in that of facilitation payments. Facilitation payments are small bribes but make no mistake about it, they are bribes....more
FINCEN PROPOSES CUSTOMER DUE DILIGENCE RULE -
On July 30, FinCEN released a proposed rule that would amend BSA regulations to clarify and add customer due diligence (CDD) obligations for banks and other financial...more
Welcome to the July 2014 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP.
This month on the anticorruption front, two Noble Corporation executives settle with the U.S. Securities and Exchange...more
Although passed in 1977, the Foreign Corrupt Practices Act (FCPA) was not significantly enforced until 2005. Since then, the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have made up for the...more
Anti-Corruption Digest is an update distributed on a monthly basis by Dorsey & Whitney providing a summary of the latest developments in anti-corruption enforcement activity around the world.
In This Issue:
Chinese anti-corruption efforts historically targeted recipients of bribes, particularly government officials. In the past year, however, Chinese authorities have initiated a very public crackdown on bribe payers in the life...more
Several recent multi-million dollar settlements with companies to resolve bribery violations illustrate how the Securities and Exchange Commission (SEC) is keeping its focus on internal controls and the accounting provisions...more
On March 19, the DOJ announced that Marubeni Corporation, a Japanese trading company, agreed to plead guilty to violating the FCPA by participating in a seven-year scheme to bribe high-ranking government officials in...more
The trial of Victor Dahdaleh in London has collapsed due to the absence of key prosecution witnesses.
The UK’s Serious Fraud Office (SFO) recently dropped its case against Victor Dahdaleh, the British-Canadian...more
The SEC knows that it has broad enforcement authority. In the FCPA arena, the SEC has civil authority over bribes, but more importantly, enforcement authority over books and records and internal controls. It is this latter...more
Today I want to use the story of The Sussex Vampyre as the starting point for an inquiry into the recent Archer-Daniels-Midland Corp (ADM) Foreign Corrupt Practices Act (FCPA) enforcement action. In the story, Holmes receives...more
Forgive me for taking the FCPA Paparazzi to task but when they deserve it, they deserve it.
A quick diversion — I often am asked by fellow bar members and commenters if I am referring to them as being a member of the...more
FCPA practitioners pick through the pages and words underlying FCPA enforcement actions to look for clues, for new policies and government strategies. It is a worthwhile process – the government sends important messages in...more
Marked by leadership changes, high-profile trials, and shifting priorities, 2013 was a turning point for the Enforcement Division of the Securities and Exchange Commission (the “SEC” or the “Commission”). While the results of...more
In my final post of 2013, I reviewed all of the individual Foreign Corrupt Practices Act enforcement actions which occurred in the past year. In this first post of 2014, I review all the corporate enforcement actions in 2013....more
This year had the largest number of individual Foreign Corrupt Practices Act (FCPA) enforcement actions since 2010, the year of the Gun Sting case. Here are the highlights of FCPA related enforcement actions against...more
Last week, it was announced by the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) that it had settled an enforcement action with Archer-Daniels-Midland Company (ADM). The DOJ resolved a criminal...more
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