Foreign Corrupt Practices Act
FCPA Release 10-03: Foreign Agents as Foreign Officials
The Department of Justice released its latest FCPA Opinion Release. The requesting company for this opinion release is stepping into a situation full of FCPA red flags. In the end, the DOJ opined that it would not bring an enforcement action based on the safeguards put in place by the company. The company is involved… » Read More
It Does Not Take Much to Get You Into FCPA Trouble
The recent FCPA enforcement actions brought against Veraz Networks, Inc. shows that it does not take huge piles of money to get in trouble. Veraz admitted to making improper payments of only $40,000. Not that $40,000 is an insignificant amount. It just pales in comparison to the huge dollars we have seen on other FCPA… » Read More
FCPA Opinion Procedure Release 10-01
The Department of Justice released its latest Opinion Procedure Release under the Foreign Corrupt Practices Act. It’s one of the quirks of the FCPA that you can ask the Department of Justice whether a particular situation would be a violation of the FCPA. This opinion is also quirky. The company requesting the opinion was in… » Read More
Daimler Charged with FCPA Violations
Daimler AG, the parent company of Mercedes-Benz, has been charged with violations of the Foreign Corrupt Practices Act. The Department of Justice accuses the company of engaging in a long-standing practice of paying bribes worth tens of millions of dollars to foreign officials in over 22 countries. There is an April 1 hearing in U.S…. » Read More
Blue Collar or White Collar
Undercover agents, wire taps and search warrants. For a criminal case it sounds like your typical organized crime investigation. You would expect the indictment to have charges for drug dealing, racketeering, murder or something similar. But last week we heard that these were the techniques used to catch the 22 people indicted for violations of… » Read More
But Everyone Else is Doing it
In my hasty post on last week’s FCPA sting operation my focus was on the aggressive use of an undercover operation to catch violations of the Foreign Corrupt Practices Act. That was big news. It’s the first time that’s happened. The indictments did not disclose the companies involved. It’s now clear that this sting operation… » Read More
DOJ Nets 22 in FCPA Sting
“The largest single investigation and prosecution against individuals in the history of DOJ’s enforcement of the Foreign Corrupt Practices Act” The Department of Justice has gotten serious about the FCPA. “This ongoing investigation is the first large-scale use of undercover law enforcement techniques to uncover FCPA violations and the largest action ever undertaken by the… » Read More
2009 Year-End FCPA Update
In case you missed it, 2009 was full of FCPA enforcement actions and trials. The Department of Justice and Securities and Exchange Commission worked hand in hand over the past year bringing actions for FCPA violations. They set a record by bringing more FCPA prosecutions during 2009 than in any prior year in the FCPA’s… » Read More
FCPA: Overcoming the Toughest Issues
Bruce Carton and SecurtiesDocket presented this informative webinar. The panelists were: – Hank Walther, Dept. of Justice – Larry Urgenson, Kirkland & Ellis – Elliot Leary, KPMG Forensic – Phil Desing, KPMG Forensic The panel started of with parallel international investigations. This is a new topic because for years there was no other country enforcing… » Read More
Canada’s Foreign Corrupt Practices Act
In the United States, the Foreign Corrupt Practices Act has received significant attention due to some recent high-profile prosecutions. Just to the North, there is the Canadian equivalent to the FCPA: the Corruption of Foreign Public Officials Act. It has not yet been a significant concern for most businesses that fall within its jurisdiction. But… » Read More
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Compliance Building is published by Doug Cornelius, focusing on compliance and ethical issues for private equity real estate companies. Read more in About.
