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.
Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA
Lessons Learned from the BizJet Executives FCPA Enforcement Actions
SEC News - Five Year Enforcement Limitation, FCPA Charges for Foreign Nationals, More...
Glenn Ware on Threat Management
Transaction Monitoring Under the FCPA
Corporate Law Report: Economic Espionage Act, Top FCPA Enforcement Actions, Trademark Audits, and More
The Eli Lilly FCPA Enforcement Action-Lessons Learned
Corporate Law Report: Mobile App Privacy, HR & the FCPA, Insider Trading, First Sale Doctrine, More
Mike Koehler on FCPA Enforcement
Esquenazi Five Factor Test for a State Owned Enterprise under the FCPA
Companies with existing compliance programs are starting to focus on the importance of monitoring, auditing and improving their compliance programs....more
Trying to avoid the unusually strict import controls in Argentina and facilitate faster clearance of its products through customs, a subsidiary of Ralph Lauren Corp. was found to have bribed local officials between 2005 and...more
One does not have to look very far in the business world to come across the phrase “Know Your Customer.” A company certainly needs to know if an entity that it may sell products or provide services to will pay for those...more
Kevin J. Napper is a shareholder in Carlton Fields' Tampa, Fla., office. He has practiced in the areas of white collar criminal defense, governmental investigations, internal investigations, and complex civil trial law for...more
On May 7, 2013, the U.S. Attorney's Office for the Southern District of New York (SDNY) unsealed extraordinary criminal charges against two registered representatives of a U.S. broker-dealer and a high-level Venezuelan...more
Despite Russia’s reputation for corruption, the anti-bribery climate in Russia is evolving. A recent flurry of anti-bribery legislation, as well as Russia’s ratification of the OECD Convention on Combating Bribery of Foreign...more
In this presentation: - Introduction - Trademark/Brand Strategy and Protection - U.S. Foreign Corrupt Practices Act and Anti-Corruption - Cross-Border Tax Planning and Compliance Please see...more
Introduction: High Pressure Regulatory Environment - Now more than ever, there is increased regulatory pressure on organizations – and their Boards of Directors – to create and maintain effective ethics and compliance...more
When acquiring a health care company doing business abroad, there is no such thing as being too thorough with anti-corruption due diligence. The Department of Justice and the Securities and Exchange Commission have the...more
To say I am excited would be putting it mildly. Yes that most premier of compliance related conferences is on the short horizon; Compliance Week 2013 is nearly upon us. It will be from May 20-22 at the Mayflower Hotel in...more
Last week, a subsidiary of American fashion designer Ralph Lauren Corporation made global news for violations of The Foreign Corrupt Practices Act of 1977 ("FCPA"). In short, FCPA prohibits covered entities – i.e., those that...more
Multinational businesses are subject to a patchwork of laws of the various jurisdictions in which they operate. Complying with the myriad rules and regulations can be challenging. Compliance obligations vary from one country...more
On January 1, 2013, Russia implemented an amendment to its anti-corruption laws that appears to go beyond the reach of both the U.S. Foreign Corrupt Practices Act (“FCPA”) and the U.K. Bribery Act (“UKBA”) to the extent it...more
The bottom-line: If you do not conduct a risk assessment, then you should start praying. The FCPA Guidance made it clear – conduct a risk assessment and tailor your compliance program to the risk assessment....more
On April 22, the DOJ and the SEC announced parallel actions against a clothing company to resolve allegations that a subsidiary of the company paid bribes to Argentine officials over a several-year period to obtain improper...more
Legal News: Eye on China Quarterly Newsletter offers companies helpful insight as they successfully navigate China’s complex and ever-changing legal and regulatory environment. In this issue, we focus on the following...more
This past week, my second book, “Best Practices Under the FCPA and Bribery Act” was released. Over the past few years I have tried to provide the compliance practitioner with solid information that can be used to implement,...more
On April 22, the U.S. Securities and Exchange Commission (SEC) announced its first non-prosecution agreement (NPA) with a company in a matter involving alleged violations of the U.S. Foreign Corrupt Practices Act (FCPA). The...more
Over the past three months, the aircraft manufacturer Boeing has gone through a public relations nightmare and financial disaster over the failure of lithium-ion batteries in its new flagship aircraft, the 787. This Boeing...more
In the two most recent corporate Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to communicate not only what they believe constitutes a...more
Not much beats the ancient Greek House of Atreus for dramatic gore: infanticide, patricide, fratricide, filicide, matricide, cannibalism, incest and about every other horror which can befall one family occurs in the various...more
For the first time, the SEC has entered into a Non-Prosecution Agreement (NPA) with a company relating to misconduct under the Foreign Corrupt Practices Act (FCPA). The SEC decided not to prosecute Ralph Lauren Corporation...more
Often, enforcement officials at the SEC and the Justice Department express their wish that securities law violators own up to their (mis)conduct as soon it comes to light. That is, come to the government and explain what has...more
BizJet self-disclosed to the DOJ, engaged in what the DOJ termed “extraordinary cooperation” and remediated the people and conduct in question. Further, DuBois and Uhl not only offered themselves up but actively worked with...more
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