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Microsoft Foreign Corrupt Practices Act (FCPA)

Thomas Fox - Compliance Evangelist

Bribery Schemes from 2019 FCPA Enforcement Actions

In today’s blog post, I want to look at some of the more unusual bribery schemes from Foreign Corrupt Practices Act (FCPA) enforcement actions in 2019. Some of these schemes were not unusual but they were accomplished with...more

The Volkov Law Group

FCPA 2019: A Record Year in Enforcement and Compliance (Part I of III)

The Volkov Law Group on

Happy New Year!! In the FCPA arena, 2019 was a record year – in enforcement and compliance. Many continuing trends are becoming more than trends – meaning they are turning into established practices....more

Faegre Drinker Biddle & Reath LLP

3 FCPA Compliance Lessons From Microsoft's Settlement

Microsoft’s recent settlement with the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) over violations of the Foreign Corrupt Practices Act (FCPA) sheds light on the DOJ’s new Corporate Enforcement...more

The Volkov Law Group

Episode 104 -- A Deep Dive into the Microsoft FCPA Settlement

The Volkov Law Group on

On July 22, 2019, Microsoft finally resolved its FCPA enforcement action with a whimper. Notwithstanding prior suggestions that Microsoft’s investigation uncovered global conduct, Microsoft’s liability focused primarily on...more

A&O Shearman

Technology Company Resolves DOJ And SEC FCPA Allegations, With Hungary Subsidiary Entering Three-Year, Monitor-Free NPA

A&O Shearman on

On July 22, 2019, the United States Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced that they had resolved allegations of Foreign Corrupt Practice Act (“FCPA”) violations against...more

The Volkov Law Group

Five Lessons for Third-Party Distributor Risk Management from Microsoft FCPA Settlement (Part III of III)

The Volkov Law Group on

The Microsoft FCPA settlement, while not significant in the total penalty of approximately $25 million, provides some important instructions concerning distributor and re-seller risks and mitigation strategies.  ...more

Thomas Fox - Compliance Evangelist

Drum Solo Week 5: Ringo and The End – Microsoft FCPA Settlement – Part 4

Initially, it would not seem that much was new or different about the Microsoft FCPA enforcement action but through this exploration, I think some clear lessons have emerge. The first is around internal controls. Here there...more

The Volkov Law Group

Microsoft FCPA Settlement Underscores Third-Party Risks (Part II of III)

The Volkov Law Group on

Microsoft’s bribery and controls violations reflect significant risks facing companies that rely on distributor and reseller networks to sell their products.  Companies often enter and operate in emerging markets through...more

Thomas Fox - Compliance Evangelist

Drum Solo Week 4: In-A-Gadda-Da-Vida – Microsoft FCPA Settlement – Part 3

Continuing our use of great drum solos to consider the Microsoft Foreign Corrupt Practices Act (FCPA) enforcement action, today we consider what Microsoft did to obtain their result. We have previously considered the...more

The Volkov Law Group

Microsoft Pays DOJ and SEC $25 Million to Resolve FCPA Violations (Part I of III)

The Volkov Law Group on

Microsoft finally resolved its FCPA enforcement action with a whimper.  Notwithstanding prior suggestions that Microsoft’s investigation uncovered global conduct, Microsoft’s liability focused primarily on Microsoft’s conduct...more

Thomas Fox - Compliance Evangelist

Drum Solo Week 3: Los Endos and Microsoft FCPA Enforcement Action – Part 2 – The Bribery Schemes

Microsoft Hungary agreed to pay approximately $8.5 million to the DOJ. Together with the amounts paid to the SEC in profit disgorgement, the total is just over $25 million. Microsoft Hungary received a 25% discount off the...more

Robins Kaplan LLP

Financial Daily Dose 7.23.2019 | Top Story: Apple to Buy Intel’s Smartphone Modem Chip Division

Robins Kaplan LLP on

Apple is in “advanced talks” to snap up Intel’s smartphone-modem chip business, a portfolio “of patents and staff valued at $1 billion or more.” The deal, should it close, would go far in prepping Apple for the arrival of...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

FCPA Predictions for 2019

The Volkov Law Group on

Here we go – another year, another set of predictions. Who knows whether they will come true? Actually, I went back and read my annual prediction posting for 2018 and 2017, respectively. Some things I called correctly, and...more

The Volkov Law Group

2018 FCPA Predictions (Part II of II)

The Volkov Law Group on

I always take a deep breath when starting this posting – not that I am the kiss of death, but sometimes my predictions come true and most times they do not. But with that caveat, I am brave enough to venture into 2018 and...more

The Volkov Law Group

Predictions for Anti-Corruption Enforcement for 2016

The Volkov Law Group on

In all honesty, if I were betting on my predictions, I would be broke. If I were setting the line on the Super Bowl, I am sure I would go bankrupt in paying off bets. With such confidence, you may want to just click to the...more

Thomas Fox - Compliance Evangelist

Good-Bye to Maureen O’Hara and How to Drive Compliance into the DNA of Your Company

Maureen O’Hara died this week. To anyone who has ever watched The Quiet Man on St. Patrick’s Day, she will always be known as Mary Kate Danaher, who was pursued and eventually wed by John Wayne. Testament to the fiery...more

The Volkov Law Group

DOJ’s Warning to High-Tech Companies: SAP Official Pleads Guilty To FCPA Violation

The Volkov Law Group on

When DOJ acts, they like to make a splash. While the FCPA Paparazzi have been lamenting the “slow down” in FCPA enforcement actions and the increase in case closings, DOJ still makes its mark when it acts, and I expect more...more

Thomas Fox - Compliance Evangelist

McNulty’s Maxim No. 3 and Response to Allegations of Bribery

In a Wall Street Journal (WSJ) article by Chris Matthews, Joe Palazzolo and Shira Ovide, entitled “U.S. Probes Microsoft Bribery Allegations”, they reported that the Department of Justice (DOJ) and Securities and Exchange...more

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