COMPLIANCE INTO THE WEEDS-EPISODE 48-THE HALLIBURTON FCPA ENFORCEMENT ACTION
Highlights from the Oral Argument in Halliburton v. Erica P. John Fund
One takeaway of the Halliburton-Sonangol FCPA enforcement action? Trust but verify....more
Along with the anti-bribery provisions, the U.S. Foreign Corrupt Practices Act (“FCPA”) contains accounting provisions that apply to publicly traded companies. These provisions require that companies maintain and adhere to...more
The Department of Justice (DOJ) ended its probe of Net1 UEPS Technologies, according to SEC filings from the South African-based payment processing company. The company received a declination from the Securities and Exchange...more
In this episode, Matt Kelly and I explore last week’s announcement by the Securities and Exchange Commission (SEC) of the resolution of its outstanding Foreign Corrupt Practices Act (FCPA) enforcement action with Halliburton...more
On July 27, 2017, the Securities and Exchange Commission (“SEC”) brought an enforcement action against Halliburton Company, a Houston-based oilfield services corporation. Specifically, the SEC alleged that Halliburton...more
Last week’s announcement by the Securities and Exchange Commission (SEC) of the resolution of its outstanding Foreign Corrupt Practices Act (FCPA) enforcement action with Halliburton Company continues to resonate and provide...more
June Foray died this week. You may not think you have heard of her but let me assure you; you have heard her. Foray was the voice of Rocket J. Squirrel in perhaps the greatest cartoon show ever, Rocky and Bullwinkle....more
Enforcement of the Foreign Corrupt Practices Act was a high priority for the Department of Justice and the Securities and Exchange Commission in 2016. There's interest in how the new administration could impact enforcement as...more
In recent years, U.S. and Western European military spending has decreased as military spending in other parts of the world has risen. As a result, aerospace, defense and government services (ADG) companies increasingly rely...more
On April 5, 2016, the U.S. Department of Justice (DOJ) issued an Enforcement and Guidance Plan (Plan) concerning the Foreign Corrupt Practices Act (FCPA). While the new Plan could be interpreted as a novel departure from past...more
Which play in Shakespeare’s cannon presents the biggest clash of cultures, which leads to the most catastrophic result? I would have to opine Othello, one of the great tragedies in all of Shakespeare. Othello, a Moor and...more
FCPA enforcement will likely take a turn into the private equity industry. I know this is a regular claim by FCPA practitioners but we already can see the beginning of the trend. The “princeling” investigations are...more
When does bribery and corruption move from a business issue to a political issue to a national issue? Why should US companies be held to the gold standard of anti-corruption laws? Should the US government even care if US...more
Oil is hovering around $50 per barrel. For most of the US economy this drop in oil price has provided a much-needed economic boost. One piece on the NPR website, entitled “Oil Price Dip, Global Slowdown Create Crosscurrents...more
For busy in-house counsel and compliance professionals, we have tried to summarize the most important international anti-corruption developments in the past month with links to primary resources. November was definitely a...more
The Department of Justice (“DOJ” or the “Department”) just issued its most recent FCPA Opinion Release, only the second in 2014. The Requestor, a publicly traded U.S. consumer products company, sought an opinion as to whether...more
Today I conclude my three-part series on mergers and acquisitions under the Foreign Corrupt Practices Act (FCPA) with a review of the post-acquisition phase. Previously many compliance practitioners had based decisions in...more