News & Analysis as of

Bribery Charitable Donations

The Volkov Law Group

Novartis Settles False Claims Act Cases and Pays $729 Million for Domestic Bribery Schemes

The Volkov Law Group on

We have a new poster-child for a defective corporate culture of wrongdoing.  Novartis has joined the exclusive club, along with Siemens, General Motors, Wells Fargo, and others in the misconduct Hall of Fame. ...more

The Volkov Law Group

C-Suite Misconduct Results in Sociedad Quimica Y Minera FCPA Resolution with DOJ and SEC

The Volkov Law Group on

In an unusual FCPA enforcement action, the Justice Department and the SEC resolved FCPA violations against Sociedad Quimica y Minera, a Chilean chemical and mining company, for a total of $30.5 million, for paying...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

King & Spalding

SEC Cracks Down on Charitable Contributions under the FCPA - Best Practices In Light of Recent SEC Enforcement

King & Spalding on

For the first time, the Securities and Exchange Commission has brought an FCPA enforcement action premised entirely on a one-time charitable contribution. On September 20, 2016, the SEC announced a settled FCPA...more

Morgan Lewis

Lessons Learned from Nu Skin

Morgan Lewis on

The enforcement action against manufacturer Nu Skin Enterprises highlights the risks of making charitable donations in high-risk countries without conducting meaningful anticorruption due diligence....more

The Volkov Law Group

Three Key Takeaways from the Nu Skin FCPA Settlement for a Corrupt Charitable Donation

The Volkov Law Group on

In a rare enforcement action, the SEC settled an FCPA enforcement action for $766,000 for a charitable donation of $154,000 to improperly influence a high-ranking Chiese Communist party official to prevent a provincial agency...more

The Volkov Law Group

FCPA Compliance: Does “Anything of Value” Really Mean “Anything of Value”?

The Volkov Law Group on

The FCPA statute is not as vague as some contend. I remember the words of a former FTC Chairperson who told me once – “The Clayton Act is not vague. I just read the law and apply it to the facts.”...more

Thomas Fox - Compliance Evangelist

Like a Rolling Stone and Charitable Donations Under the FCPA

Today we celebrate one of the seminal achievements in rock and roll for it was on this day, 50 years ago, in 1965 that Bob Dylan recorded his single Like a Rolling Stone. Columbia Records executives initially rejected the...more

Thomas Fox - Compliance Evangelist

Supermarket To The World – The ADM FCPA Enforcement Action

Last week, it was announced by the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) that it had settled an enforcement action with Archer-Daniels-Midland Company (ADM). The DOJ resolved a criminal...more

Thomas Fox - Compliance Evangelist

Transaction Monitoring Under the FCPA

Transaction monitoring was mentioned in a couple of significant enforcement actions of 2012. I think that it will move to becoming a best practice in FCPA compliance programs. This video will explain how transaction...more

Thomas Fox - Compliance Evangelist

Internal Audit Review of Charitable Donations Under the FCPA

When is a rose not a rose? When it is a charitable donation not made for philanthropic purposes and it violates the Foreign Corrupt Practices Act (FCPA). I thought about that concept when reviewing the Eli Lilly and Company...more

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