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Internal Controls China

Morrison & Foerster LLP

DOJ National Security Division Issues First-Ever Declination Under Voluntary Self-Disclosure Policy

On May 22, 2024, the Department of Justice’s (DOJ) National Security Division (NSD) announced its first-ever prosecution declination under its corporate voluntary self-disclosure (VSD) policy for sanctions and export controls...more

Bradley Arant Boult Cummings LLP

Philips Agrees to Pay $62M to Settle FCPA Books-and-Records Violations from Efforts to Win Chinese Contracts

Koninklijke Philips N.V., a global medical technology manufacturer, recently agreed to pay over $62 million to resolve a Foreign Corrupt Practices Act (FCPA) enforcement action with the Securities and Exchange Commission...more

The Volkov Law Group

Episode 276 -- Review of Phillips and Franks Int'l SEC FCPA Settlements

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The SEC recently announced two separate FCPA SEC enforcement actions -- the first against Franks International for $8 million for FCPA violations in Angola; and the second against Philips, a Dutch medical device company, for...more

American Conference Institute (ACI)

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - July 21st - 22nd, Boston, MA

ACI is excited to welcome you back in-person to the 14th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, taking place on July 21–22, 2022 in Boston! Legal and compliance professionals from...more

Morgan Lewis

Key Strategies and Considerations for Chinese Companies Preparing for and Responding to a Subpoena

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It is the prerogative of government authorities—US and non-US alike—to demand information from individuals or organizations and seek the assistance of courts to enforce compliance. Although such demands take various forms,...more

Thomas Fox - Compliance Evangelist

Corruption, Crime & Compliance - Episode 208 - A Deep Dive into the WPP FCPA SEC Settlement

In this episode, Michael Volkov reviews the WPP SEC FCPA settlement. WPP, the Largest Global Advertising Group, Settles FCPA Charges with SEC for $19.2 Million. After a long hiatus, the SEC announced a settlement with WPP...more

K2 Integrity

What the Biden Administration Brings on Sanctions

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Despite a shift in the sanction landscape, it will take time for enforcement activity to catch up. As a result, organizations should regularly examine their exposure with business partners around the globe and consult with...more

A&O Shearman

SEC Reaches $8.8 Million Settlement With Pharmaceutical Company To Resolve Allegations Of FCPA Violations

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On February 28, 2020, the U.S. Securities and Exchange Commission (“SEC”) announced a settled administrative proceeding with an Ohio-based pharmaceutical company, Cardinal Health, Inc. (“Cardinal”) over alleged violations of...more

The Volkov Law Group

Cardinal Health Pays SEC $8.8 Million for FCPA Violations

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Cardinal Health (“Cardinal”) agreed to pay the SEC $8.8 million for FCPA violations in China relating to its internal controls and books and records. Cardinal acknowledged facts relating to internal controls deficiencies and...more

Hogan Lovells

Luxury retailers in Hong Kong and neighboring markets face Coronavirus crisis

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Over the past nine months in Hong Kong, luxury retailers have encountered a challenging market. Hong Kong has traditionally been a popular destination for Mainland Chinese seeking to purchase luxury goods, but recent...more

Thomas Fox - Compliance Evangelist

Top SEC Enforcement Actions from 2019

Yesterday, I considered five Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) enforcement actions. Today, I want to look at key FCPA enforcement actions by the Securities and Exchange Commission (SEC)....more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 5: Lessons Learned for the Compliance Professional

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 3: Internal Control Failures

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

Thomas Fox - Compliance Evangelist

Former Herbalife Employees Indicted on FCPA Violations

China continues to be a high-risk location for US companies to do business. While the current administration has laid numerous tariffs on Chinese goods, the fact that it holds 6 billion potential consumers will continue to...more

Robins Kaplan LLP

Financial Daily Dose 10.10.2019 | Top Story: US/China Trade Talks Resume Even as Tensions Grow

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Senior negotiators from the U.S. and China will officially resume trade negotiations today, “with higher tariffs looming if [they] fail to break a five-month stalemate.” The U.S.’s moves this week to blacklist 28 Chinese tech...more

Robins Kaplan LLP

Your Daily Dose of Financial News

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US trade negotiations with China have stalled such that the anticipated meeting between the countries’ leaders is, according the White House, “highly unlikely” to occur before the March 1 deadline marking the end of a 90-day...more

Robins Kaplan LLP

Your Daily Dose of Financial News

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The Fed wrapped its January meetings yesterday with the expected news that it would leave the benchmark interest rate unchanged and the less-guaranteed report that it was hitting the pause button on future rate hikes (aka,...more

Robins Kaplan LLP

Your Daily Dose of Financial News

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Nissan’s Carlos Ghosn problems now extend to the United States, where the Securities and Exchange Commission has opened a probe into the accuracy of the company’s financial disclosures and internal controls....more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - November 2018

ANTICORRUPTION DEVELOPMENTS - Deputy Attorney General Rod Rosenstein Announces Pursuing Individuals Will be a “Top Priority” for Corporate Enforcement Actions - On November 29, 2018, Deputy Attorney General Rod J....more

Robins Kaplan LLP

Your Daily Dose of Financial News

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Amazon announced yesterday that it will immediately raise the minimum wage it pays to all 250,000 of its employees (and the 100k it plans to hire for the holiday season) to at least $15/hour, more than double the current...more

Thomas Fox - Compliance Evangelist

The Credit Suisse FCPA Enforcement Action: Part III – The Result and Going Forward

Last week Credit Suisse Group AG (CSAG) and Credit Suisse (Hong Kong) Limited (CSHK), a subsidiary of CSAFG, settled a Foreign Corrupt Practices Act (FCPA) enforcement action for just over $77 million for the illegal hiring...more

The Volkov Law Group

Lessons Learned From FCPA Enforcement Against JP Morgan for Sons and Daughters Referral Program

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Last week, the Justice Department and the SEC finally brought to a close the Sons and Daughters or Princelings investigation. Pending investigations against four other companies still remain to be resolved....more

Thomas Fox - Compliance Evangelist

John Fogarty Rocks-Nu Skin Informs Oversight

I recently saw John Fogerty in concert. For those you are not aware, he was a founding member and the driving force behind Creedence Clearwater Revival (CCR), one of the very top American groups from the 1960s and early...more

Thomas Fox - Compliance Evangelist

Declinations and Profits Disgorgement – It Was There All Along

Last week there were two declinations issued by Department of Justice (DOJ) for Foreign Corrupt Practices Act (FCPA) matters. The matters involved two Texas based, privately held companies. The first was HMT LLC (HMT) which...more

Thomas Fox - Compliance Evangelist

Enforcement Week III: Johnson Controls FCPA Enforcement Action – Part 2

I continue my review of the Johnson Controls, Inc. (JCI) Foreign Corrupt Practices Act (FCPA) enforcement action today by focusing on the Department of Justice’s (DOJ’s) Declination to Prosecute. Yesterday, I considered the...more

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