A high-level U.S. Department of Justice (“DOJ”) official recently stated that a Foreign Corrupt Practices Act (“FCPA”) Corporate Enforcement Policy, which incentivizes self-disclosure, also applies to U.S. companies merging...more
Two months ago, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”), working with the U.S. Attorney’s Office for the Northern District of California (“USAO”), assessed a civil money penalty of over $110...more
The single most frequently asked question by our international clients over the past several months is whether there will be changes in white collar prosecution priorities under the new administration, specifically with...more
Action Item: The Securities and Exchange Commission’s enforcement action against Goodyear Tire & Rubber Company and its investigation of Mondelez International provide key lessons to U.S. companies seeking to acquire foreign...more
3/11/2015
/ Books & Records ,
Bribery ,
Corporate Counsel ,
Disgorgement ,
Due Diligence ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Entities ,
Foreign Subsidiaries ,
Goodyear ,
Internal Controls ,
Popular ,
Securities and Exchange Commission (SEC) ,
Settlement
Action Item: In November 2014, the United States Department of Justice issued an Attorney General Opinion with respect to the enforcement of the Foreign Corrupt Practices Act. ...more
On July 28, 2014, Smith & Wesson Holding Corp. (“Smith & Wesson”), the firearms manufacturer based in Springfield, Massachusetts, agreed to resolve charges brought by the Securities and Exchange Commission (“SEC”) for...more