Due Diligence, Charitable Donations, Foreign Corrupt Practices Act (FCPA)

31 Days to a More Effective Compliance Program - Charitable Donation Enforcement Actions

Thomas Fox - Compliance Evangelist on 5/19/2020

When is a rose not a rose? When it is a charitable donation not made for philanthropic purposes and violates the FCPA. This was a feature of the Eli Lilly and Company (Lilly) FCPA enforcement action brought by the SEC in...more

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

The Volkov Law Group on 1/31/2017

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

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

King & Spalding on 10/4/2016

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

Lessons Learned from Nu Skin

Morgan Lewis on 10/3/2016

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

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

The Volkov Law Group on 9/23/2016

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

Like a Rolling Stone and Charitable Donations Under the FCPA

Thomas Fox - Compliance Evangelist on 6/16/2015

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

From China to Poland and Brazi l- The Lilly FCPA Enforcement Action- Part II

Thomas Fox - Compliance Evangelist on 1/3/2013

In Parts II and III of my review of the Eli Lilly and Company (Lilly) Foreign Corrupt Practices Act (FCPA) enforcement action brought by the Securities and Exchange Commission (SEC), I will discuss some the processes and...more

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