The Foreign Corrupt Practices Act Bribery

The Foreign Corrupt Practices Act is a United States Federal law enacted in 1974 to create transparency and prevent bribery for U.S.-based corporations conducting business overseas.
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Joint Venture Partners And The Company You Keep Under The FCPA

As the father of a teenage daughter I am sometimes, reluctantly, forced to admit that upon rare occasions my parents were right about a few things. One was asking for permission first rather than asking for forgiveness after...more

HP, Three Subsidiaries Pay $108 Million To Settle FCPA Charges

The Russian, Polish and Mexican subsidiaries of Hewlett-Packard Company resolved criminal FCPA charges with the Department of Justice while the parent corporation settled with the SEC. ZAO Hewlett-Packard A.O., or HP Russia,...more

Japanese Trading Company Pleads Guilty In DOJ FCPA Enforcement Action

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

Marubeni Plea Agreement Suggests There May Be More FCPA Charges to Come

In a March 19, 2014 Plea Agreement, the Japanese trading company Marubeni Corporation agreed to plead guilty in the U.S. District Court for the District of Connecticut to a criminal information charging a conspiracy to...more

Marubeni Gets Hit Again for FCPA Violations - DOJ Says the Company Did Not Voluntarily Disclose the Conduct and Refused to...

In a courtroom in New Haven, Connecticut, on March 19, 2014, Marubeni Corporation (Marubeni), a storied Japanese trading company headquartered in Tokyo, pleaded guilty to an eight-count criminal information charging Marubeni...more

Avoid the Quick Fix: Addressing Government Contracting Ethical Breaches That Can Destroy A Business

For the last 15 years, the Foreign Corrupt Practices Act (FCPA) has garnered the most “compliance” attention by companies and the media due to the severe penalties associated with the bribing of foreign government officials....more

ATM Maker To Settle FCPA and Sanctions Violations

Automated teller machine maker NCR Corp. has agreed to settle charges of Foreign Corrupt Practices Act (FCPA) and U.S. sanctions violations. In 2012, a whistleblower accused the company's board members and executives of...more

Just Say No: Refusing To Pay Bribes

I was never a big fan of the Reagan Administration’ solution to America’s drug problem – Just Say No. The phrase was a simple solution to a more complex problem, one that people now recognize as a health problem rather than...more

What Happens In Ecuador Does Not Stay In Ecuador

In last week’s decision in Chevron v. Donziger, the court enjoined the enforcement of a $9.5 billion Ecuadorian judgment against Chevron Corp. for environmental pollution, alleged to have been caused by its predecessor,...more

Red Notice Newsletter - March 2014

This month on the anticorruption front, a New York court orders two former Siemens executives to pay record civil penalties in a bribery case involving the company’s Argentina business; Canada prosecutes former executives...more

Bribery Is Bribery

FCPA practitioners, commentators and yes, even the FCPA Paparazzi, all spend a lot of time discussing, analyzing and posing theoretical questions related to the legal issue of who is a “foreign official” under the FCPA. The...more

Where O’ Where Is The Board Of Directors?

If you trace the path of an FCPA violation inside an organization, at a minimum, you will see a path of lost opportunities, oversights and omissions. If you see anything different, you may be looking at a deliberate scheme...more

Welcome To The Hotel California: FCPA Enforcement

This past weekend I saw The Eagles on their ‘History of The Eagles’ Tour. It truly was that, a complete musical history of the group, from the beginning in 1971 up until now. They played for well over 3 hours and it was...more

How to Accurately Identify the Corrupt Intent Behind Bribery: Real Life Cases, Anti-Bribery Training

As I mentioned in my last blog, FCPA expert Tom Fox was recently asked in an interview by Corporate Compliance Insights to define the criteria for what constitutes a bribe under the FCPA. He outlined three key criteria: Is...more

The SEC’s Enforcement Of An Elastic “Internal Controls” Requirement

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

Shirley Temple And Excellence In FCPA Training Video

Today we honor one of the most interesting personalities of the 20th century, Shirley Temple, who died yesterday. She was probably the greatest child actress of all-time, being the lead grossing star for five straight years...more

The Simon-Sting Tour And New Information In Your Compliance Program

This past weekend I saw the first show in a multi-city tour by Sting and Paul Simon. I have never been a big Sting or Police fan but I am a huge Paul Simon fan, in all his musical incarnations. As it was their first show,...more

Crude Allegations: Corruption in the Energy Trading Sector

The world-wide energy trading sector, where traders match physical supply and demand of energy by purchasing, reselling, and moving commodities (crude oil and refined products, natural gas, coal, and even electricity) across...more

The Engineer’s Thumb And How To Bribe

We conclude our week of Sherlock Holmes inspired themes with one of the few cases in which Holmes fails to bring the criminals to justice, The Adventure of the Engineer’s Thumb. Once again using the Holmes tale as a...more

The Sussex Vampyre And The ADM FCPA Settlement

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

The So-Called Re-Emergence Of Gifts, Meals And Entertainment As A Compliance Problem

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

Walk a Straight Line — Even if All Roads Are Crooked

The person who said "When in Rome, do as the Romans do" did not have to contend with the U.S. Foreign Corrupt Practices Act (FCPA). Although bribery is an integral part of daily life in many countries and can seem a...more

Naval Theorists And The Measurement Of Compliance

If are interested in naval history, strategy and tactics, I have a question for you: Are you a disciple of Alfred Mahan or Julian Corbett? If you are a Mahanian, you probably focus on large naval engagements or the great...more

Business Gifts

Business courtesies are an important way to cement good working relationships between those who do business together. Inappropriate gifts can have negative consequences for your organization and business partner...more

Alcoa Subsidiary Pleads Guilty to FCPA Charge, Will Pay $348 Million

On January 9, Alcoa World Alumina LLC, a majority-owned and controlled global alumina sales company of Alcoa Inc., agreed to plead guilty and to pay $223 million in criminal fines and forfeitures to resolve charges that it...more

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