News & Analysis as of

Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) Books & Records

Porter Hedges LLP

ComEd Settlement Proves the Foreign Corrupt Practices Act Is Not Limited to Foreign Corruption

Porter Hedges LLP on

On September 28, 2023, the Securities and Exchange Commission (“SEC”) announced that it reached a settlement with Exelon Corporation and its subsidiary, Commonwealth Edison Company (“ComEd”), relating to charges that ComEd...more

Lowenstein Sandler LLP

Trade Matters -Lowenstein Sandler's Global Trade & National Security Newsletter - June 2023

Lowenstein Sandler LLP on

Crypto Asset Company Settles Sanctions Violations for $7.5 million- On May 1, the U.S. Department of Foreign Assets Control (OFAC) announced a $7.5 million settlement with crypto asset company Poloniex LLC for 65,942 apparent...more

Bradley Arant Boult Cummings LLP

Philips Agrees to Pay $62M to Settle FCPA Books-and-Records Violations from Efforts to Win Chinese Contracts

Koninklijke Philips N.V., a global medical technology manufacturer, recently agreed to pay over $62 million to resolve a Foreign Corrupt Practices Act (FCPA) enforcement action with the Securities and Exchange Commission...more

Orrick, Herrington & Sutcliffe LLP

SEC fines tech company $2.5 million to settle FCPA charges

On May 26, the SEC announced that a Connecticut-headquartered tech research and consulting company (the “settling company”) agreed to pay nearly $2.5 million to settle claims that it violated the anti-bribery, books and...more

Orrick, Herrington & Sutcliffe LLP

SEC fines Dutch medical supplier $62 million to settle FCPA charges

The SEC recently announced that a global Dutch manufacturer of health technology products agreed to pay more than $62 million to settle claims that it allegedly violated the FCPA with respect to the sale of medical diagnostic...more

Bass, Berry & Sims PLC

FCPA Enforcement Update: Two Big Settlements to End the Year 

Bass, Berry & Sims PLC on

In the past several years there has been a significant decrease in Foreign Corrupt Practices Act (FCPA) enforcement efforts. Reports suggest that corporate criminal cases have decreased by roughly 50% since 2012. FCPA...more

Paul Hastings LLP

Ephemeral Messaging at the Office: Avoiding Pitfalls and Establishing Best Practices

Paul Hastings LLP on

Users of ephemeral messaging applications may intend that their messages be—as the word “ephemeral” suggests—short lived, but the real-world consequences and legal ramifications from improper use of such apps can be anything...more

The Volkov Law Group

Oracle’s FCPA Violations: A Lesson in Managing Third-Party Distributor Risks (Part II of II)

The Volkov Law Group on

Oracle’s SEC settlement for $23 million underscores the power of the FCPA provisions mandating effective internal controls and accurate books and records.  As everyone knows, these provisions can be applied to a wide-range of...more

Thomas Fox - Compliance Evangelist

Corruption, Crime, and Compliance - A Deep Dive into KT Corp's SEC Settlement for FCPA Violations

The SEC announced the first FCPA enforcement action in 2022. South Korean telecommunications company, KT Corporation, agreed to pay $6.3 million to settle FCPA violations. As part of the settlement, KT Corp. agreed to pay...more

The Volkov Law Group

KT Corp. Settles SEC FCPA Case for $6.3 Million (Part I of III)

The Volkov Law Group on

The SEC announced its first FCPA enforcement action in 2022. South Korean telecommunications company, KT Corporation, agreed to pay $6.3 million to settle FCPA violations.  As part of the settlement, KT Corp. agreed to pay...more

Thomas Fox - Compliance Evangelist

Corruption, Crime & Compliance - Episode 208 - A Deep Dive into the WPP FCPA SEC Settlement

In this episode, Michael Volkov reviews the WPP SEC FCPA settlement. WPP, the Largest Global Advertising Group, Settles FCPA Charges with SEC for $19.2 Million. After a long hiatus, the SEC announced a settlement with WPP...more

The Volkov Law Group

WPP, the Largest Global Advertising Group, Settles FCPA Charges with SEC for $19.2 Million (Part I of III)

The Volkov Law Group on

After a long hiatus, the SEC announced a settlement with WPP plc, the world’s largest advertising group, for FCPA violations in India, China, Brazil and Peru for $19.2 million.  The SEC’s resolution charges WPP with...more

The Volkov Law Group

Deutsche Bank Agrees to Pay $130 Million to Resolve FCPA and Fraud Cases (Part I of II)

The Volkov Law Group on

Deutsche Bank, the infamous German bank connected to President Trump, settled FCPA and fraud cases with the Justice Department and the SEC, and agreed to pay a total of $130 million....more

The Volkov Law Group

DOJ Hits Beam Suntory with FCPA Settlement for $19.5 Million (Part I of II)

The Volkov Law Group on

Beam Suntory, a global producer and distributor of distilled beverages, settled its FCPA case with DOJ for $19.5 million for bribes paid in India.  The DOJ settlement follows an SEC FCPA settlement for $8 million announced...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 1 – Introduction

Herbalife Nutrition Ltd (Herbalife) recently concluded a long running Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC). Herbalife...more

The Volkov Law Group

Herbalife Settles FCPA Charges and Agrees to Pay $123 Million (Part I of III)

The Volkov Law Group on

DOJ and the SEC settled concluded its long-pending FCPA investigation of Herbalife Nutrition Ltd (“Herbalife”). ...more

The Volkov Law Group

World Acceptance Corporation Settles FCPA Charges with the SEC for $21.7 Million

The Volkov Law Group on

World Acceptance Corporation (“WAC”), a US-based consumer loan company, agreed to pay the SEC $21.7 million for FCPA violations in Mexico.  WAC’s cited violations covered the full gamut of FCPA violations, including bribery...more

Thomas Fox - Compliance Evangelist

Alexion Pharmaceuticals FCPA Enforcement Action: Part 2 – Data Analytics

The same day that the 2020 Resource Guide was released, the Securities and Exchange Commission (SEC) announced it had settled a Foreign Corrupt Practices Act (FCPA) enforcement action involving Alexion Pharmaceuticals Inc....more

The Volkov Law Group

Alexion FCPA Violations: Lessons Learned (Part II of II)

The Volkov Law Group on

The Alexion Pharmaceutical SEC FCPA enforcement action represents another in the long line of enforcement actions against drug and device companies.  The drug and device industries have been – and will continue to be — easy...more

The Volkov Law Group

Alexion Pays SEC $21 Million for FCPA Violations (Part I of II)

The Volkov Law Group on

Notwithstanding the pandemic and remote working arrangements, the Securities and Exchange Commission is continuing to bring FCPA enforcement actions....more

Stinson LLP

SEC Charges Company for Undisclosed Perquisites

Stinson LLP on

In a settled enforcement action, the SEC charged Argo Group International Holdings, Ltd. with failure to disclose perquisites provided to its CEO and board member, Mark E. Watson III. In an interesting twist, the SEC charged...more

Ballard Spahr LLP

Consumer lender sets aside $21.7 million to settle Foreign Corrupt Practices Act probe

Ballard Spahr LLP on

South Carolina-based consumer lender World Acceptance Corporation announced recently that it had earmarked $21.7 million to resolve a Securities and Exchange Commission (SEC) probe into its compliance with the Foreign Corrupt...more

McDermott Will & Emery

[Webinar] Anti-Corruption and Compliance Training - May 28th, 10:00 am - 11:30 am EDT

McDermott Will & Emery on

Please join McDermott and Grant Thornton on Thursday, May 28, for a webinar training on anti-corruption and compliance. This training will discuss the auditing standards on illegal acts by clients and the auditor’s...more

Thomas Fox - Compliance Evangelist

Recidivist Eni: Corruption, Controls and Books and Records

Eni S.p.A (Eni) joined the two-time Foreign Corrupt Practices Act (FCPA) loser ranks last week when it agreed to a Cease and Desist Order (Order) with the Securities and Exchange Commission (SEC) for violations of the...more

The Volkov Law Group

Cardinal Health Pays SEC $8.8 Million for FCPA Violations

The Volkov Law Group on

Cardinal Health (“Cardinal”) agreed to pay the SEC $8.8 million for FCPA violations in China relating to its internal controls and books and records. Cardinal acknowledged facts relating to internal controls deficiencies and...more

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