As highlighted in this prior post, in 2012 medical devices maker Smith & Nephew plc (a U.K. company with ADR shares traded on the New York Stock Exchange) resolved a $22 million Foreign Corrupt Practices Act enforcement action concerning conduct in Greece. According to the DOJ, “Smith & Nephew, through certain executives, employees and affiliates, agreed to sell products at full list price to a Greek distributor based in Athens, and then pay the amount…
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 one consequence of the overall financial ramifications of FCPA scrutiny and enforcement. As highlighted in this prior post, in late 2019 Swedish telecom company Ericsson (a company with American Depositary Shares traded in the U.S.)…
The FCPA Flash podcast provides in an audio format the same fresh, candid, and informed commentary about the Foreign Corrupt Practices Act and related topics as readers have come to expect from written posts on FCPA Professor. This FCPA Flash episode is a conversation with Matthew Galvin (Global Vice President, Ethics & Compliance at AB-InBev). During the podcast, Galvin talks about the company’s BrewRight compliance system including: the origins of BrewRight; what BrewRight is; and…
Here in Packerland, there is much angst over the apparent reluctance of Aaron Rodgers to return to the Green Bay Packers as quarterback. This is no small matter as Rodgers is the reigning NFL MVP and … well … this is Packerland. Some Packer fans are not sitting on the sidelines as passive observers. For instance, Mr. Brews Taphouse is offering Rodgers (along with his fiance) free burgers and beer for life if he agrees…