It’s always useful to look at what your competition is doing. The same is true in drafting your code of conduct (or code of...
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Foreign Corrupt Practices Act
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...
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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...
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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 Justice...
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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...
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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 anti-bribery laws. There are...
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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...
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FCPA Conviction
Gerald Green and Patricia Green, Los Angeles-area film executives, were found guilty of conspiracy to violate the Foreign Corrupt Practices Act and money laundering laws of the United States, as well as substantive violations of the FCPA and U.S. money laundering laws. The verdict was handed down late on Friday.
The Greens were charged by the...
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New Liability Under the FCPA: Control Person Liability
The SEC charged Nature’s Sunshine Products Inc. with violating the Foreign Corrupt Practices Act after its Brazilian subsidiary made cash payments to customs officials to get their products imported into the country. The SEC also included two officers of the company in those charges. That part of the case was fairly standard.
What was new...
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Control Components Inc. and the FCPA
Control Components Inc. pleaded guilty to violating the anti-bribery provisions of the Foreign Corrupt Practices Act and the Travel Act, admitting to bribing foreign officials in a decade-long scheme.
As part of the plea agreement, Control Components agreed to pay a criminal fine of $18.2 million; create, implement and maintain a comprehensive anti-bribery compliance program;...
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FCPA Opinion Procedure Release 09-01
The Department of Justice released its latest Opinion Procedure Release under the FCPA: 09-01
The Requestor designs and manufactures a specific type of medical device. The Requestor’s competitors already operate and sell their products to the government of a certain foreign country and the Requestor wants to enter that market.
A senior government official laid out...
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Compliance Building is published by Doug Cornelius. Read more in About. Feel free to say to him at his speaking engagements. Upcoming Conferences:
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