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Subsidiaries Securities and Exchange Commission (SEC) Compliance

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

Lowenstein Sandler LLP

Effective and Efficient Pre-Transaction FCPA Diligence: How to Leverage Compliance and ESG to Avoid Buyer’s Remorse and Other...

Lowenstein Sandler LLP on

The arduous process of FCPA compliance requires risk teams to digest and cross-reference a morass of information – from internal data analysis to human representatives collecting interviews on the ground. Diligence failures...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments For July 2020

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

Skadden, Arps, Slate, Meagher & Flom LLP

Ericsson Agrees To Pay Over USD $1 Billion To Settle FCPA Charges

On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more

Thomas Fox - Compliance Evangelist

Top SEC Enforcement Actions from 2019

Yesterday, I considered five Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) enforcement actions. Today, I want to look at key FCPA enforcement actions by the Securities and Exchange Commission (SEC)....more

The Volkov Law Group

Ericsson Pays $1 Billion for Systemic FCPA Violations (Part I of II)

The Volkov Law Group on

The Sweden-based telecommunications company, Ericsson, agreed to a pay a total of $1 billion (yes, billion with a “B”) for FCPA violations.  Ericsson entered into settlement agreements with DOJ and the SEC.  Ericsson agreed...more

WilmerHale

Juniper FCPA Settlement Provides Useful Compliance Reminders

WilmerHale on

On August 29, 2019, the Securities and Exchange Commission (“Commission” or “SEC”) agreed to resolve an enforcement action against Juniper Networks, Inc. (“Juniper” or the “Company”), a Silicon Valley-based cybersecurity and...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

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

A&O Shearman

SEC Settles FCPA Allegations Concerning Allegedly Improper Payments By Company's Indian Subsidiary

A&O Shearman on

On July 2, 2018, Chicago-based spirits maker Beam Suntory Inc. (“Beam Suntory” or the “Company”) agreed to pay $8.2 million to settle Foreign Corrupt Practices Act (“FCPA”) claims brought by the Securities and Exchange...more

NAVEX

Landmark SEC Decision Cites Compliance, Diligence in Decision Not to Prosecute FCPA Violations

NAVEX on

In a remarkable affirmation of the value of robust compliance and due-diligence programs, the Securities and Exchange Commission last month announced that it would not prosecute a U.S. company for potential violations of the...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

Dorsey & Whitney LLP

Goodyear Settles SEC FCPA Charges

Dorsey & Whitney LLP on

Goodyear Tire and Rubber Company settled FCPA books and records and internal control charges with the SEC. The settlement reflects the extensive cooperation and remedial efforts of the company. In the Matter of Goodyear Tire...more

Mintz - Securities & Capital Markets...

Goodyear’s Settlement with the SEC Emphasizes the Importance of FCPA Due Diligence in M&A Transactions and of Having a Robust...

On February 24, 2015, Goodyear Tire & Rubber Co. agreed to pay more than $16 million to settle charges that two of its subsidiaries allegedly paid $3.2 million in bribes that generated $14,122,535 in illicit profits. The SEC...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

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 117-the Avon FCPA Enforcement Action

In this episode I take a deep dive into the recent concluded Avon FCPA enforcement action. ...more

Cadwalader, Wickersham & Taft LLP

SEC Issues Guidance on Conflict Minerals Rule

On May 30, 2013, the Securities and Exchange Commission issued guidance related to the requirement that issuers disclose the use of conflict minerals in their products, as mandated by the 2010 Dodd-Frank Wall Street Reform...more

The Volkov Law Group

Failing To Act: Lessons From 2012 FCPA Enforcement

The Volkov Law Group on

FCPA practitioners tend to repeat themselves. Some of the points we make need to be repeated, and some do not. Businesses are not able to react as quickly as they should in response to potential risks and possible...more

Thomas Fox - Compliance Evangelist

The Allianz FCPA Enforcement Action – What the Compliance Practitioner Needs to Know

Who is your favorite character from the Iliad? Is it Agamemnon the king who brings the Greek Armada to Troy for his brother’s honor; perhaps Ajax the mountain of a man who is the most loyal Greek warrior; how about Achilles...more

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