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
Last week, the U.S. Department of Justice (DOJ) announced the indictment of two employees of a U.S. broker-dealer, Direct Access Partners, and a senior official in Venezuela’s state economic development bank, Banco de...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
I often marvel at some of the stories which come up in the context of Foreign Corrupt Practices Act (FCPA) investigations and enforcement. If you made up some of the things which are reported, I fear that people might find...more
Last week, the US Department of Justice (DOJ) announced the sentencing of Paul G. Novak, a former consultant of Willbros International, Inc., a subsidiary of the Houston based Willbros Group, for his role in a conspiracy to...more
In This Issue: - FEDERAL ISSUES - STATE ISSUES - COURTS - FIRM NEWS - FIRM PUBLICATIONS - MORTGAGES - BANKING - CONSUMER FINANCE - SECURITIES - E-COMMERCE - PRIVACY/DATA SECURITY -...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
This issue of JD Supra's Corporate Law Report focuses on latest news and analysis for the Securities and Exchange Commission, including a look at: - a recent SCOTUS decision in Gabelli v. SEC ruling that the SEC only has...more
Changing SEC leadership defines its priorities for a new era of SEC enforcement. At the annual "The SEC Speaks" conference on February 22 in Washington, D.C., Acting Director George Canellos and other senior officials...more
Two recent district court decisions have shed light on the reach and scope of the U.S. Foreign Corrupt Practices Act (FCPA) over foreign nationals: SEC v. Straub and SEC v. Sharef. For companies and individuals operating...more
Last year was another busy year in health care fraud enforcement. In 2012, the Office of Inspector General for the Department of Health and Human Services (HHS-OIG) reported total expected recoveries of $6.9 billion from all...more
For years, a significant number of Foreign Corrupt Practices Act (FCPA) enforcement actions have focused on or involved the People’s Republic of China (PRC), Chinese subsidiaries, or Chinese officials. It is hard to avoid...more
FCPA practitioners tend to repeat themselves. Some of the points we make need to be repeated, and some do not. Businesses are not able to react as quickly as they should in response to potential risks and possible...more
As the second term of the Obama administration begins, the SEC is experiencing a profound leadership transition, with the departures of agency Chair Mary Schapiro; Director of Enforcement Robert Khuzami; its general counsel;...more
I always like to make predictions at the beginning of each year. My track record is plus and minus – sometimes on target, sometimes off-target. The biggest story in the last five years has been the rise of FCPA...more
In the last five years, law firms and companies have aggressively added resources and capabilities to respond to increased FCPA enforcement and compliance needs. Outside counsel have established practice areas dedicated...more
This Part III is the final installment of my review of the Eli Lilly and Company (Lilly) FCPA enforcement action brought by the Securities and Exchange Commission (SEC). In this Part III, I will review the FCPA issues that...more
In Parts II and III of my review of the Eli Lilly and Company (Lilly) Foreign Corrupt Practices Act (FCPA) enforcement action brought by the Securities and Exchange Commission (SEC), I will discuss some the processes and...more
Who is your favorite character from the Iliad? Is it Agamemnon the king who brings the Greek Armada to Troy for his brother’s honor; perhaps Ajax the mountain of a man who is the most loyal Greek warrior; how about Achilles...more
As you see from today’s picture I am enthusiastically wearing a New England Patriots (classic) shirt. You may ask yourself why am I wearing this shirt? The reason is because of a rather rash wager I made with Jay Rosen, Vice...more
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