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
One FCPA compliance topic we are often asked about by clients is how government investigations start. The U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have developed a number of mechanisms...more
On May 29, the DOJ and the SEC announced that a French oil and gas company will pay nearly $400 million to resolve allegations that the company made illegal payments through third parties to an Iranian official in exchange...more
The UK Government has announced a review of the Bribery Act 2010 and its intent to reduce the cost of compliance for small and medium-sized businesses. The main focus will apparently be on facilitation payments. These are...more
Today I finalize my review of the Total SA (Total) Foreign Corrupt Practices Act (FCPA) enforcement action....more
In This Issue: - AUDITOR LIABILITY - CLASS ACTIONS - CONFIDENTIAL WITNESSES - DEMAND FUTILITY - DERIVATIVE LITIGATION - FEDERAL TORT CLAIMS ACT - FOREIGN CORRUPT PRACTICES ACT - INSIDER TRADING...more
Much of the coverage of the recent Foreign Corrupt Practices Act case against Ralph Lauren Corp. (RLC) focused on the fact that both the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) awarded it...more
Yesterday I reviewed the facts surround Total SA’s (Total) lengthy bribery scheme to win contracts in Iran....more
On May 29, 2013, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) announced agreements with Total S.A. (Total) to settle alleged Foreign Corrupt Practices Act (FCPA or the Act) violations for a...more
This week the Securities and Exchange Commission (SEC) and the Department of Justice (DOJ) announced that France-based oil and gas company Total S.A. resolved Foreign Corrupt Practices Act (FCPA) charges by agreeing to pay a...more
In this issue: - SEC Approves FINRA Rule Change That Requires Reporting OTC Equity Transactions Within 10 Seconds - NFA Issues Notice to Members Regarding Section 16 Financial Requirements for Cleared Swaps...more
Remember 1995? It was a long time ago, so you can be forgiven for not recalling much of it. To re-orient you: it was President Clinton’s first term; the Oklahoma City bombing happened in April; a jury found O.J. Simpson not...more
The recent prosecution of two registered broker-dealers and a Venezuelan government official for FCPA violations underscores a point I often make – nothing good ever happens when the government has a reason to look around in...more
The nightmare of every corporate director is to wake up to find out that the company of the Board he or she sits on is on the front page of a national newspaper for alleged illegal conduct. ...more
Synopsis - This article examines the anti-bribery legislation of three countries, the United States, Canada, and the United Kingdom. The legislation of the three countries is compared and virtually all the criminal...more
In Brief - The Foreign Corrupt Practices Act covers a nearly boundless range of business conduct by issuers and their agents in an ever more global world. Yet the contrast in sentences handed down in two recent FCPA...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
The FCPA Paparazzi has been at it again – it is fascinating to watch the reaction of practitioners and commentators in the FCPA arena. ...more
On May 7, the DOJ charged two employees of a U.S. broker-dealer and a senior official in Venezuela’s state economic development bank for their alleged roles in what the DOJ describes as a “massive international bribery...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
Last week saw a significant Foreign Corrupt Practices Act (FCPA) enforcement action against employees of a US broker-dealer, who are alleged to have bribed a Venezuelan government official to direct brokerage to the firm. The...more
In This Issue: - FEDERAL ISSUES - STATE ISSUES - COURTS - MISCELLANY - FIRM NEWS - FIRM PUBLICATIONS - MORTGAGES - BANKING - CONSUMER FINANCE - SECURITIES - PRIVACY/DATA SECURITY -...more
Chief Compliance Officers are usually very proud of their anti-corruption training programs. Most companies rely on a combination of live and on-line training programs to communicate the message of compliance....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
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
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