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Harry Cassin
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Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

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Senior Editor

Richard L. Cassin
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Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
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Marc Alain Bohn
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Bill Waite
Contributing Editor

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Russell A. Stamets
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2008 FCPA Enforcement Index

Eleven organizations were named in Foreign Corrupt Practices Act enforcement actions during 2008 by the Justice Department, the Securities and Exchange Commission, or both. All of the companies on our list resolved their enforcement actions, except privately-held Nexus Technologies Inc.

View the full report here. 

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  1. The index is a good referencer. Thnx, but i do not read anything on a latest potential problem with Satyam Computers (an Indian Software Services Company) that is banned for 8 years by World Bank on Corruption charges and colluding with the CIO of World Bank.

  2. Satyam has not been subject to an FCPA enforcement action.

  3. You listed Grynberg vs. BP et al. In a more recent case, on 20 November 2008, the same Mr. Grynberg included a RICO Cause of Action tied to an alleged FCPA violation, in Grynberg, et al. vs Ivanhoe Energy Inc., et al., in the Federal Dist. Ct. for the District of Colorado, File: 1:08-cv-02528 -WDM-BNB. The Complaint, among other things, alleges that at least one of the Defendants violated the FCPA in order to gain a competitive business advantage.

    The scheduling conference is set for February 10, 2009, at 10:00 a.m in Courtroom A-401, Fourth Floor, United States Courthouse, 901 19th Street, Denver, Colorado.

    The referrence to the FCPA is contained in paragraph 39: “Upon information and belief, … violated the U.S. Foreign Corrupt
    Practices Act, 15 U.S.C. § 78 et seq. …, by bribing government officials, ….” This allegation is apparently tied to the RICO Cause of Action in paragraph 64(a) of the Complaint.

  4. In the enforcement actions listed, do we know whether any Books and Records (B&R) violations were alleged without allegations made under the anti-bribery (AB) provisions?

    It is unclear to me whether the B&R provisions are used primarily as a fall back when DOJ/SEC can't tie the payments to a public official or show the requisite quid pro quo (and thus, I assume, there would be cases without AB allegations). Or whether the B&R provisions are used primarily as part of DOJ/SEC negotiations once they can show that the AB provisions have been violated.



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