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China Meals-Gifts-and Entertainment Rules

The Volkov Law Group

Herbalife’s FCPA Settlement: Lessons Learned (Part III of III)

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Herbalife’s FCPA settlement is another one for books – the wreckage left includes two criminal indictments for Chinese officials who may never be apprehended, along with $123 million in penalties....more

The Volkov Law Group

Ericsson’s Pervasive Bribery Conduct: The Toxic Mix of Senior Executive Involvement and Third Party Corruption (Part II of II)

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Ericsson’s FCPA settlement is in the books (not the books and records).  But it casts a significant shadow across the FCPA landscape.  A pervasive and systemic culture of bribery is defined to reflect senior executive...more

The Volkov Law Group

DOJ Charges Two Herbalife Executives with Criminal FCPA Violations

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Last week, DOJ announced the indictment of two former Herbalife executives in China for participating in a bribery scheme over a ten-year period.  Herbalife, a multi-level marketing company, was not charged and its...more

Thomas Fox - Compliance Evangelist

Former Herbalife Employees Indicted on FCPA Violations

China continues to be a high-risk location for US companies to do business. While the current administration has laid numerous tariffs on Chinese goods, the fact that it holds 6 billion potential consumers will continue to...more

Thomas Fox - Compliance Evangelist

How to garner a NPA and Declination: Akamai and Nortek – Part I

It certainly did not take long for companies to see the benefit of the Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) Pilot Program around FCPA enforcement as this week there where two public declinations...more

The Volkov Law Group

Doing Business in China Should Be “Scary”

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Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for another posting on corruption risks in China. A little fear is healthy. It will keep you vigilant and aware. At this point if corporate...more

BCLP

SEC Settlement Sends a Strong Message to Companies: Treat Princelings and Commoners Alike, or Pay Dearly

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On March 1, 2016, the SEC announced that Qualcomm Incorporated, a San Diego-based wireless telecommunication product company, agreed to pay $7.5 million to settle charges that its actions violated the Foreign Corrupt...more

Dorsey & Whitney LLP

Qualcomm Settles FCPA Charges With SEC

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Gifts and hospitality continue to be a key theme in the SEC’s latest FCPA case. The action also involves hiring relatives of officials and ignoring risk in the face of a weak compliance and internal control environment. In...more

Dorsey & Whitney LLP

Yates Memo in Action: No Cooperation Credit in FCPA Enforcement for Failing to Disclose Key Facts

Dorsey & Whitney LLP on

A recent case illustrates both the ongoing corruption risks for U.S. companies doing business in developing countries such as China and the Government’s tougher stance on settling white collar crime cases. In this case, the...more

The Volkov Law Group

PTC Settlement: Compliance Reminders for Internal Controls, Travel and Gifts

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PTC, a Massachusetts software company, reached settlements with the SEC and DOJ last week for FCPA violations for a total of $28 million. Interestingly, the SEC announced a DPA with a PTC official who assisted in the...more

Morrison & Foerster LLP

Lessons from DOJ’s FCPA Resolution with PTC China: No Partial Self-Disclosure Credit

In 2015, the Department of Justice (DOJ) made more news for the corporate Foreign Corrupt Practices Act (FCPA) cases that it did not bring than for the two that it did bring: Nine times last year, DOJ declined to join...more

Thomas Fox - Compliance Evangelist

More FCPA Grief Involving Gifts, Travel & Entertainment: PTC in China – Part III

I have been exploring the PTC Inc. Foreign Corrupt Practices Act (FCPA) settlement this week. It included a Non-Prosecution Agreement (NPA) from the Department of Justice (DOJ) with two Chinese subsidiaries and a Cease and...more

Dorsey & Whitney LLP

Travel, Entertainment, Gifts Yield DOJ, SEC FCPA Charges Again

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Travel, entertainment and gifts tied to inadequate controls are recurrent themes in FCPA cases. Many of these cases involve the use of agents and center in China. Each of these recurrent items appear in the most recent FCPA...more

Thomas Fox - Compliance Evangelist

More FCPA Grief Involving Gifts, Travel & Entertainment: PTC in China – Part I

Sometimes you have to wonder just how long it will take before US companies realize (1) there is a Foreign Corrupt Practices Act (FCPA) and (2) it applies in China as yesterday both the Department of Justice (DOJ) and...more

Thomas Fox - Compliance Evangelist

Blood on the Tracks Hits No. 1 and the Lessons Learned from SciClone

On this week in 1975, Bob Dylan’s 15th studio album, Blood on the Tracks, reached the Number 1 album slot on the Billboard charts. This was in spite of no song rising above the 31st slot on the single charts. It came out in...more

The Volkov Law Group

SciClone Pharmaceuticals: A Textbook Case of FCPA Violations for Gifts, Meals, Entertainment and Travel

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The Securities and Exchange Commission continues its steady march as the prominent FCPA enforcement agency against corporations.  The Justice Department has not brought any enforcement actions this year and continues to...more

Manatt, Phelps & Phillips, LLP

White Collar Enforcement Omnibus Edition—Cyber Crimes, Sanctions and Spoofing, Oh My!

Why it matters: Since our last newsletter, a lot has been going on in white collar enforcement… so much so that we decided to devote an entire newsletter to it. It was a month of superlatives. The DOJ and the SEC announced...more

The Volkov Law Group

Four Clear Messages from Bristol Meyers Squibb FCPA Enforcement Action

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The SEC’s FCPA enforcement action for $14.6 million against Bristol Meyers Squibb (“BMS”) in China provides a textbook example of how things can go wrong in China. For the compliance practitioner (as well as CEO and...more

Dorsey & Whitney LLP

SEC, Bristol-Myers Settle FCPA Charges

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FCPA procedures, internal controls and travel, entertainment and gifts were at the center of the SEC’s latest FCPA action. The action names as a Respondent Bristol-Myers Squibb Company and focuses on its efforts to sell...more

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