SEC administrative settlements in the FCPA context were rare prior to 2010 largely because the SEC could not impose monetary penalties in such proceedings absent certain exceptions.
However, in the Dodd-Frank Wall Street Reform Act of 2010 Congress granted the
On June 9th, I will be participating in a free webinar hosted by Lextegrity titled “Exploring the Mechanisms Used to ‘Fund’ Bribery Schemes.”
Generally speaking, a corporate bribery scheme often involves the creation of a “pot of money” within a
Foreign Corrupt Practices Act settlement amounts are one obvious consequence of FCPA non-compliance and tend to generate the most headlines.
However, as has been discussed on these pages for years including in this article “FCPA Ripples”, settlement amounts are only
Early in my professional career, a mentor told me that some of the most intense professional disagreements involve matters in which so little is actually at stake.
I was reminded of this upon reading the funny pissing match about the best
As highlighted in this prior post, in October 2015 Millicom, a telecom and media company headquartered in Luxembourg with shares traded on a U.S. exchange, disclosed:
“Millicom … announced that it has reported to law enforcement authorities in the
One reason to take FCPA enforcement agency rhetoric with a grain of salt is because it is warranted.
For instance, the FCPA enforcement agencies often talk about the importance of x and how they are committed to x, but in
As highlighted in this prior post, in February 2018 Albemarle Corp. (a North Carolina based chemical company) disclosed Foreign Corrupt Practices Act scrutiny.
Specifically the company disclosed:
“Following receipt of information regarding potential improper payments being made by third
As highlighted in this prior post, in January 2018 the DOJ announced that Mark Lambert (pictured – a former co-president of Transport Logistics International) was criminally charged with Foreign Corrupt Practices Act and related violations for his alleged “role
