News & Analysis as of

Subsidiaries Foreign Corrupt Practices Act (FCPA) Alstom

WilmerHale

Second Circuit Limits Reach of FCPA’s Anti-Bribery Provisions Charged Under Agency Principles

WilmerHale on

On August 12, 2022, the US Court of Appeals for the Second Circuit issued another decision in a long-running criminal action that holds significant implications for the reach of the US Foreign Corrupt Practices Act (FCPA)...more

McDermott Will & Emery

District Court Judge Highlights FCPA's Limits

A recent US District Court for the District of Connecticut decision reveals the practical limits of the Foreign Corrupt Practices Act (FCPA) in cases involving foreign nationals, foreign conduct and complex multinational...more

Eversheds Sutherland (US) LLP

Hoskins escapes FCPA convictions while money laundering convictions remain

On February 26, 2020, the US District Court for the District of Connecticut reinforced the Second Circuit’s recent decision to limit prosecutors’ ability to pursue Foreign Corrupt Practices Act (FCPA) charges against foreign...more

Dorsey & Whitney LLP

UPDATE: Trial Court Overturns Former Alstom Executive’s Foreign Corrupt Practices Act Convictions

Dorsey & Whitney LLP on

Former Alstom SA executive Lawrence Hoskins’s jury convictions under the Foreign Corrupt Practices Act (“FCPA”) were set aside on February 26, 2020, by Judge Janet Bond Arterton of the United States District Court for the...more

Foley Hoag LLP

Foreign Executive’s FCPA Convictions Overturned

Foley Hoag LLP on

District Court Finds Insufficient Evidence That He Acted As Agent of U.S. Subsidiary - Background - On February 26, 2020, a federal judge in Connecticut granted in part the motion for acquittal of a former senior executive...more

BCLP

Judge Overturns FCPA Conviction on Lack of Evidence of Agency

BCLP on

In a closely followed case, on February 26, 2020, a District Court Judge in Connecticut granted Lawrence Hoskins’ motion for acquittal on the seven FCPA counts on which the jury convicted him. Hoskins was a UK citizen who...more

Barnea Jaffa Lande & Co.

United States: Enhanced Enforcement Policy regarding Anti-Corruption and Bribery Law on Non-US Citizens and Companies

Last November, a Connecticut jury convicted Mr. Hoskins on six counts of bribing a foreign public official under the Foreign Corrupt Practices Act (FCPA), and on three counts of money laundering. This is an important red...more

Dorsey & Whitney LLP

Former Alstom Executive Convicted of Foreign Corrupt Practices Act Charges on Agency Theory

Dorsey & Whitney LLP on

Lawrence Hoskins, a British citizen and former employee of French conglomerate Alstom SA, has been found guilty by a federal jury in Connecticut of 11 of 12 criminal charges, including six counts of violating the United...more

Eversheds Sutherland (US) LLP

Shortening the long arm of the law - the Second Circuit limits the extraterritorial reach of the Foreign Corrupt Practices Act

On August 24, 2018, the US Court of Appeals for the Second Circuit in United States v. Hoskins rejected the government’s broad reading of the Foreign Corrupt Practices Act (FCPA) and ruled that a foreign national without ties...more

Morrison & Foerster LLP

Top Ten International Anti-Corruption Developments for July 2016

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras

In this episode, Compliance Week Editor-in-Chief Matt Kelly and I discuss the Avon and Alstom FCPA enforcement actions and then take a look at the ongoing Petrobras corruption scandal and what it means for Brazil. ...more

Bradley Arant Boult Cummings LLP

Alstom Guilty Plea Sends Strong Message that DOJ Has Harsh View of Inadequate Internal Controls and Failure to Fully Cooperate

On December 22, 2014, French power and transportation company Alstom S.A. (“Alstom”) pleaded guilty to violating the Foreign Corrupt Practices Act (“FCPA”) and agreed to pay $772.29 million, the largest criminal fine ever...more

Thomas Fox - Compliance Evangelist

Byzantium and the Alstom FCPA Settlement – Part III

Porphyry is a type of stone that was much favored in the Roman world. In a review of several books in the New York Review of Books, entitled “The Purple Stone of Emperors”, Peter Brown looked into the history of the lithic in...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 118-the Alstom FCPA Enforcement Action

In this episode 118, I take a deep dive into the Alstom FCPA enforcement action and its implication for the CCO and compliance practitioner. I also discuss comments from Dick Cassin and the FCPA Professor on the case. ...more

Thomas Fox - Compliance Evangelist

The Alstom FCPA Enforcement Action – Part I

As the first blog post of 2015, I thought it appropriate to highlight two outstanding confluences. The first is that this year is the centenary of the birth of Orson Welles. While not occurring in 2015, near the end of 2014...more

Foley & Lardner LLP

Alstom’s FCPA Guilty Plea and Fine of $772 Million Offer Compelling Lessons

Foley & Lardner LLP on

The December 23, 2014, announcement by the U.S. Department of Justice (DOJ) that Alstom, S.A., a French power and transportation company, pled guilty to two Foreign Corrupt Practices Act (FCPA) charges and agreed to pay $772...more

Proskauer - Corporate Defense and Disputes

Alstom to Pay Largest FCPA Criminal Penalty in History

Earlier this week, Alstom S.A., a French multinational power and transportation company, pleaded guilty in the District of Connecticut to a two-count information charging it with violating the accounting provisions of the...more

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