For just the second time in the Foreign Corrupt Practices Act’s (FCPA) history, a company was charged with FCPA offenses based solely on a charitable contribution that was intended to buy the influence of a foreign...more
The Securities and Exchange Commission (“SEC”) recently announced that two companies agreed to pay penalties of more than $500,000, combined, for illegally requiring employees to waive their rights to monetary awards from the...more
After a relatively slow year of Foreign Corrupt Practices Act (FCPA) prosecutions in 2015, this year started out with a landmark settlement against telecommunications provider VimpelCom Ltd. DC Partner Mark Srere, Denver...more
7/22/2016
/ Alcoa ,
Alstom ,
Benchmarking ,
Chief Compliance Officers ,
Compliance ,
Corporate Counsel ,
Enforcement Actions ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
KBR (formerly Kellogg Brown & Root) ,
Siemens ,
VimpelCom
On June 9, 2016, the United States Securities and Exchange Commission announced its second largest award under the agency’s Dodd-Frank Whistleblower Program. This is the largest such award issued since the SEC issued a $30...more
In the past week, the SEC has issued two multimillion dollar awards to whistleblowers. The announcement of two significant awards in quick succession suggests that the “significant uptick” in in the number of tips noted by...more
So you want to use the government’s EB-5 Immigrant Investor Program (“EB-5 Program”) to raise cash? Be aware that the SEC will be looking over your shoulder to determine whether you are acting as an unregistered broker-dealer...more
On Tuesday, March 8, 2016, in conjunction with announcing a recent $2 million whistleblower award, Sean McKessey, Chief of the Office of the Whistleblower, stated that the SEC continues to see “a significant uptick” in the...more
When asked about the relatively slow year of Foreign Corrupt Practices Act (“FCPA”) prosecutions in 2015, the Chief of the DOJ Criminal Division’s Fraud Section suggested last month: “one year isn’t long enough to tell the...more
2/23/2016
/ Bribery ,
Civil Forfeiture ,
Corporate Counsel ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Government Officials ,
Securities and Exchange Commission (SEC) ,
Telecommunications ,
VimpelCom
Last week, the SEC announced an award of $700,000 to a company outsider who conducted a “detailed analysis” resulting in a successful SEC enforcement action. In a press release, Andrew Ceresney, director of the SEC’s Division...more