This previous post highlighted the $9.9 million Foreign Corrupt Practices Act enforcement actions against Deere & Co. concerning subsidiary conduct in Thailand.
This post highlights additional issues to consider.
No Prior Disclosure
It is rarely a surprise when a publicly-traded
As highlighted in this recent post, approximately 20% of Foreign Corrupt Practices Act enforcement activity takes place in the month of September as the SEC’s fiscal year comes to a close.
In September’s first FCPA enforcement (there have been
Ever since the Foreign Extortion Prevention Act (FEPA) was proposed in Congress nearly five years ago and through its enactment in late 2023, this site has explained how FEPA was a muddy mess in terms of its statutory language. This
The Foreign Corrupt Practices Act has been around for approximately 47 years.
However, FCPA trials are rare.
Earlier this week – in Connecticut – trial began in U.S. v. Oztemel.
The trial is believed to be only the 23rd in
This recent post highlighted how the Assistant Chief of the DOJ’s FCPA Unit went to FCPA Inc.
As sure as the sun rises in the east and dogs bark – and following a well traveled career path – another Assistant
This previous post highlighted the recent $14.4 million Foreign Corrupt Practices Act enforcement actions against Boston Consulting Group (BCG) concerning conduct in Angola.
This post highlights additional issues to consider.
Voluntary Disclosure
The DOJ’s “declination with disgorgement” letter mentions “BCG’s
The Foreign Corrupt Practices Act has always been a law much broader than its name suggests.
Sure, the FCPA contains anti-bribery provisions which concern foreign bribery.
Sure, the FCPA’s books and records and internal controls provisions can be implicated in
So-called “declinations with disgorgement” (first used by the DOJ in a Foreign Corrupt Practices Act in 2016) are just another resolution vehicle – among others – used by the DOJ to resolve alleged instances of FCPA scrutiny.
The latest example
Since 2014, the FCPA Institute has elevated the Foreign Corrupt Practices Act knowledge and practical skills of professionals from around the world. The FCPA Institute began as an in-person event, but shifted to Zoom in 2020. The Zoom event is
The DOJ has a specific website devoted to the Foreign Corrupt Practices Act.
On the site you will find a purported chronological list and alphabetical list of Enforcement Actions.
With any free website (let alone a government website), there