Foreign Official, Compliance | JD Supra Law News

Failing To Act: Lessons From 2012 FCPA Enforcement

by Michael Volkov on 2/12/2013

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

Siemens Whistleblower Complaint Underscores Need for "Top-Down" Anti-Corruption Compliance

by Anthony Moshirnia | Sheppard Mullin Richter & Hampton LLP on 2/4/2013

In 2008, Siemens AG paid $800 million to settle charges that it had violated the Foreign Corrupt Practices Act, which generally prohibits bribery of foreign officials for the purpose of obtaining or retaining business. That...more

Pfizer FCPA Settlement Emphasizes the Importance of Robust Compliance Programs for the Healthcare Industry

by Bora Rawcliffe | Sheppard Mullin Richter & Hampton LLP on 1/23/2013

The healthcare industry has been under increased SEC and DOJ scrutiny lately for potential FCPA violations. What has been described as an “industry sweep,” has focused primarily on medical device and pharmaceutical companies....more

Smaller FCPA Story But We’re Sure You’re Following It: DOJ Issues New Opinion Procedure Releases

by Thad McBride, Cheryl Palmeri | Sheppard Mullin Richter & Hampton LLP on 12/6/2012

While the FCPA world – and this blog – has been abuzz thanks to the new FCPA Guide, on a relatively mundane note, the U.S. Department of Justice (DOJ) also recently issued two Opinion Procedure Releases (OPRs) with respect to...more

Flailing at the Definition of a “Foreign Official”

by Michael Volkov on 11/29/2012

Perhaps I was being overly optimistic. I thought the Justice Department and the SEC could bring a little clarity to the term “instrumentality” in the definition of a “foreign official” under the FCPA. It was wishful...more

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Foreign Official › Compliance

Failing To Act: Lessons From 2012 FCPA Enforcement

Siemens Whistleblower Complaint Underscores Need for "Top-Down" Anti-Corruption Compliance

Pfizer FCPA Settlement Emphasizes the Importance of Robust Compliance Programs for the Healthcare Industry

Smaller FCPA Story But We’re Sure You’re Following It: DOJ Issues New Opinion Procedure Releases

Flailing at the Definition of a “Foreign Official”

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