FCPA Compliance and Ethics Report-Episode 165-BHP FCPA Enforcement and Lessons Learned for the Compliance Practitioner
The case of Lungowe and others v Vedanta Resources Plc and Konkola Copper Mines Plc has just been before the Supreme Court on the question of whether the courts of England and Wales should hear this overseas claim. In...more
Chevron CEO John Watson is out in a move that leaves the energy giant without a board-confirmed successor and marks the “dramatic shift under way at big oil companies as they adapt to a prolonged period of lower prices...more
Breakingviews suggests that the devil is definitely in the details in Sempra Energy’s apparent winning bid for Oncor. Control of the company, for example, isn’t as simple as it might seem....more
Uber made waves yesterday by firing 20 employees as part of an internal investigation into sexual harassment and other unsavory aspects of its workplace culture....more
So what happens when traders attempt to manipulate the index that’s meant to measure fear in the stock market itself? Well, we might just be finding out. Two UT Austin researchers think that we’re seeing efforts to mess with...more
Mexico’s Crown Jewels: Deep Water and Farmout Tender Results - On December 5, 2016, the Comisión Nacional de Hidrocarburos (“CNH”) conducted the Opening and Presentation of Bid Proposals Ceremony for the Ronda Uno,...more
The Securities and Exchange Commission’s (SEC) recent Foreign Corrupt Practices Act (FCPA) settlements focus on companies’ lack of sufficient anti-corruption compliance programs, which means, to the SEC, that the companies...more
I. Introduction: Enforcement Trends and Priorities - Among other significant developments, 2015 saw the U.S. Department of Justice (the “DOJ” or the “Department”) document a policy priority of holding individuals...more
2015 continued the trend of Foreign Corrupt Practices Act (FCPA) enforcement actions brought by the Securities and Exchange Commission (SEC) with no parallel Department of Justice (DOJ) enforcement action. As you might...more
Despite a decline in enforcement actions by the Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the...more
A second insider trading action was brought by the Commission against a senior banking official based on the same take-over for which he was previously charged — but a different securities trading account is at the center of...more
Ed. Note-today we have a guest post from Jean-Michel Ferat ,CPA, CFF is a Managing Director in the Washington D.C office of the Claro Group around his views on the BHP Billiton enforcement action. Much has been made in...more
The creator of one of the most ubiquitous symbols of mid-century Americana died earlier this week. Don Featherstone, the creator of the pink plastic lawn flamingo, the ultimate symbol of American lawn kitsch, has died. He was...more
Today, I continue my four-part series on the above question posed to me recently by a colleague. In Part I, I wrote that only the US government had the wherewithal, tools and will to do so. Yesterday, I focused on corruption...more
In this episode I review the BHP Billiton FCPA enforcement action brought by the Securities and Exchange Commission. I review the underlying facts and provide some lessons learned for the compliance practitioner. The key...more
On May 20, BHP Billiton Ltd. and BHP Billiton Plc (BHPB), a global resources company that sponsored the 2008 Beijing Summer Olympic Games, settled Securities and Exchange Commission charges of Foreign Corrupt Practices Act...more
On May 20, 2015, the U.S. Securities and Exchange Commission (SEC) announced a $25 million settlement with Anglo-Australian natural resource extraction company BHP Billiton. The settlement resolves charges that the...more
In This Issue: - Form BE-10 Filing Deadline Extended - Delaware Supreme Court Holds That Plaintiffs Must Specifically Plead Non-Exculpated Claims Against Disinterested Directors in Transaction Under Entire...more
SEC Enforcement Action on FCPA Compliance – Check the Box Is Not Enough. On May 20 the SEC announced that global resources company BHP Billiton had agreed to pay $25 million to settle charges that it had violated the...more
The SEC is on a mission – companies that engage in egregious payment schemes for gifts, hospitality and travel are going to get prosecuted for civil FCPA violations. Recent SEC enforcement actions against companies continue,...more