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Enforcement Actions Meals-Gifts-and Entertainment Rules

The Volkov Law Group

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

The Volkov Law Group on

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

WilmerHale

$1 Billion Ericsson Resolution, Three Jury Verdicts Cap Off Busy Fourth Quarter for US FCPA Enforcement

WilmerHale on

On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...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

The Volkov Law Group on

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

Robinson+Cole Health Law Diagnosis

Government Continues to Closely Scrutinize Pharmaceutical Marketing Practices

On September 4, 2019 the Department of Justice (DOJ) announced a $15.4 million settlement with pharmaceutical company Mallinckrodt ARD LLC (Mallinckrodt) to resolve alleged violations of the Anti-Kickback Statute (AKS) in two...more

The Volkov Law Group

Juniper Networks Settles FCPA Violations with SEC for $11.7 Million

The Volkov Law Group on

Juniper Networks agreed to pay the SEC $11.7 million to settle FCPA violations for conduct occurring in Russia and China. Under the settlement, Juniper Networks agreed to disgorgement of $4 million, a $6.5 million civil...more

Thomas Fox - Compliance Evangelist

Drum Solo Week 2-Moby Dick and Microsoft FCPA Enforcement Action-Part 1

“Microsoft’s subsidiary in Hungary provided discounts on software licenses to its resellers, distributors and other third parties. Instead of passing on the discounts to Microsoft’s government customers, the discounts were...more

The Volkov Law Group

Telefônica Brasil Pays $4.125 Million for Hospitality-Related FCPA Violations

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As the old adage provides – better late than never.  (Same applies for my somewhat tardy posting on this case). Telefônica Brasil settled FCPA violations with the SEC for a pretty penny — $4.125 million in civil penalties...more

The Volkov Law Group

United Technologies SEC FCPA Enforcement Action: Gifts, Meals, Entertainment and Travel Abuse and Bribery (Part II of II)

The Volkov Law Group on

When you read through the United Technologies SEC FCPA enforcement action, you cannot help but shake your head – the level of abuse and participation by senior managers in the UT companies – Pratt & Whitney and Otis Elevator...more

Robinson+Cole Health Law Diagnosis

Recent Anti-Kickback Cases Emphasize Government Scrutiny of Speaker’s Bureaus and Lavish Meals Funded by Pharmaceutical and Device...

The Department of Justice (DOJ) recently resolved two health care fraud cases – one criminal and one civil – that demonstrate the government’s continued scrutiny of lavish meals and “speaker’s bureaus” sponsored by...more

Thomas Fox - Compliance Evangelist

Volkov on the Evolving Standards for Compliance Programs

Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more

Dorsey & Whitney LLP

This Week In Securities Litigation

Dorsey & Whitney LLP on

The Commission prevailed on a summary judgment motion this week in a case based on an offering fraud. It also filed another settled FCPA action centered on gifts, travel and entertainment provided to healthcare professionals...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

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more

Dorsey & Whitney LLP

SEC, Bristol-Myers Settle FCPA Charges

Dorsey & Whitney LLP on

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

Goodwin

Financial Services Weekly News - September 2015 #2

Goodwin on

Regulatory Developments: DOL Releases Transcripts of Fiduciary Standard Hearings - The Department of Labor (DOL) has released the transcripts of the hearings held by the agency in August on its proposed fiduciary...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

Non-Enforcement - Form PF — What Purpose? SEC registered investment advisers with at least $150 million of assets under management in private funds are required to periodically file Form PF with the SEC. The...more

Mintz

Foreign Corrupt Practices Act (FCPA): Israel Beware – Trends in Enforcement.

Mintz on

Intuitively, Israeli companies and their directors would likely assume that their businesses are immune to investigation and the assessment of penalties by US regulators that are separated by a vast ocean and located more...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 165-BHP FCPA Enforcement and Lessons Learned for the Compliance Practitioner

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

Katten Muchin Rosenman LLP

Former Olympic Games Sponsor Settles With SEC for $25 Million Over FCPA Violations

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

The Volkov Law Group

Gifts, Meals and Prosecution: BHP Billiton’s Settlement

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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

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