News & Analysis as of

The Avon FCPA Settlement, Part I

It is finally done. The long awaited Avon Foreign Corrupt Practices Act (FCPA) enforcement action is on the books. I would say what a long, strange trip it has been but that does not really seem to capture everything that...more

Avon Settles FCPA Charges with the DOJ and SEC

Travel, entertainment and gifts continue to be a central focus of FCPA enforcement. Earlier this month, and last month, the Commission filed settled FCPA actions centered on these items. Now the SEC and the DOJ have settled...more

Recent FCPA Enforcement Actions: The Layne Christensen Case and SBM Offshore

The Fourth Quarter of 2014 has been a busy one for DOJ and SEC in the FCPA arena. We are all praying that DOJ and SEC resolve the Avon case soon so that we do not have to include the case on our lists for predictions for...more

Cable Company Announces FCPA Internal Investigation Near Completion

Just a month after announcing its internal investigation of possible FCPA violations, news reports indicate that a major cable company’s review will be completed or substantially completed by the first quarter of 2015. ...more

Gordon Lightfoot, the Edmund Fitzgerald and the Bio-Rad FCPA Settlement, Part I

This month there are two dates that are forever tied together in the annuals of maritime tragedies and great songwriters. November 10 is the 39th anniversary of the sinking of the Great Lakes freighter the SS Edmund...more

How To Strengthen Your Ethics And Compliance Policy Management

People say that hindsight is 20/20. I’d say from my experiences its true. If only we could have 20/20 vision before an incident occurs, think of all the heartaches and headaches we could avoid. It would be especially helpful...more

Business Lit Ledger -- Fall 2014

In This Issue: - Promoting the False Claims Act By Dismissing Meritless Qui Tam Actions -Delaware Supreme Court Extends Shareholder Books and Records Inspection Rights to Privileged Internal Investigation...more

A Surprise in Progressive Rock – FCPA Internal Investigations

The case has a long involved Foreign Corrupt Practices Act (FCPA) history. It involves Panalpina and its customer Shell. David Smyth, in his great blog Cady Bar the Door, reported, in a post entitled “Texas Court of Appeals...more

Preservation of Legal Privilege in Corporate Investigations – A Cross Border Comparison

A D.C. Circuit decision (In re Kellogg Brown & Root, Inc.) has confirmed privilege over employee statements during in-house investigations. Can the world take comfort? This article examines privilege in the context of...more

FCPA Compliance and Ethics Report-Episode 64-Managing the Third Party Relationship Under the FCPA, Part II [Video]

In this episode I continue my review of the five steps of managing third parties under the FCPA. In this part II, I discuss steps 3-5....more

Three Practical Steps to Managing FCPA & Anti-Corruption Risks

Foreign Corrupt Practices Act (FCPA) enforcement continues to be a priority for the United States Department of Justice (DOJ) and Securities and Exchange Commission (SEC). In recent years, U.S. authorities have aggressively...more

Red Notice Newsleter

Welcome to the May 2014 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month, on the anticorruption front, Avon Products, Inc. (“Avon”) agrees to pay USD $135 million to settle a...more

Message To Companies from DOJ and SEC: Take FCPA Compliance Seriously

Federal regulators have been particularly aggressive in enforcing the Foreign Corrupt Practices Act (FCPA), making it crucial for companies to take anti-corruption training seriously. Beauty products giant Avon...more

Texas Court of Appeals Has Put Some FCPA Internal Investigations in an Awkward Spot

Given that this case was decided last summer, I can’t quite put the headline in the present tense. I’m slow to the draw on it, but I think it’s important. Last July, in Writt v. Shell Oil Co., 409 S.W.3d 59 (Tex. Ct. App....more

Internal Investigations: Doing One Can Be A Compliance Best Practice

The US Navy contract scandal took an interesting twist recently when one of its contractors, Inchcape Shipping Services, which had been suspended from doing business with the Navy for “conduct indicating questionable business...more

A Critical Requirement Of A Major Internal Investigation — Independence

There are so many potential pitfalls in conducting an internal investigation. I always say that there is an “art” to conducting an effective internal investigation. ...more

DOJ and SEC Officials Outline Considerations for Companies’ Internal Investigations

Companies all over the globe are increasingly aware of the record number of corporate criminal enforcement actions brought in recent years by enforcement authorities to combat corruption, and many companies now are also...more

Edison, The Phonograph And Supply Chain Audits

Today we celebrate Thomas Edison. It is not his birthday but the 127th anniversary of Edison announcing his first recording invention, the phonograph. ...more

Beware the False Claims Act, Whistleblowers, and the Importance of Internal Investigations

Companies that do business with the federal government must be cognizant of potential liability under the False Claims Act. Civil litigation may be inevitable at times as a result of occasional business disputes with...more

Internal Investigations In A “Bet The Company” Case

Lawyers like to be dramatic. Litigators love to be dramatic. ...more

Federal Authorities Announce FCPA Action, First SEC Non-Prosecution Agreement

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

Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA [Video]

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

Actions Taken During A FCPA Enforcement Action - Lessons From Parker Drilling And Ralph Lauren

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

The Danger Of FCPA “Proactive” Investigations

The old adage – if something is too good to be true, it probably is not – applies with equal force in the world of bribery and intrigue. The recent arrest of the mining executive for obstruction of the Justice Department’s...more

How To Demonstrate Ethics And Compliance – Earn It, Re-Earn It And Re-Evaluate It

What should your company do if it finds itself in a situation where some of its senior leadership has engaged in conduct which violates its own ethical standards or external legal standard such as the Foreign Corrupt...more

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