Marc Alain Bohn | Contributing Editor
Marc Alain Bohn is a contributing editor of the FCPA Blog.
He’s an attorney with the law firm of Miller & Chevalier in Washington, D.C. He focuses on the Foreign Corrupt Practices Act, export controls and economic sanctions, and other international trade and policy issues.
He advises U.S. and international companies on compliance and enforcement matters, including export licensing, voluntary disclosures, and internal investigations. He also works with companies to develop tailored forward-looking compliance programs with effective systems of internal control.
While attending George Washington University Law School, Marc co-founded and chaired the George Washington National Religious Freedom Moot Court Competition.
As part of its recent settlement with the SEC, Ralph Lauren Corporation agreed to disgorge $593,000 that was “obtained or retained as a result of the violations discovered during the investigation,” along with $141,846 in pre-judgment interest.
In what is thought to be the first FCPA-related enforcement action ever taken against a China-based company, the SEC entered into a joint settlement yesterday with Keyuan Petrochemicals Inc. and its former CFO, Aichun Li, over alleged violations of the books and records and internal controls provisions of the FCPA, and anti-fraud and reporting provisions of other federal securities laws.
With the assistance of Karen Polk (Miller & Chevalier’s librarian), our firm tracks the active “FCPA Docket” involving individuals, which includes all known FCPA-related ongoing prosecutions, fugitives, sentencings, and pending appeals. This information is current as of February 4, 2013.
Just over a year after Assistant Attorney General Lanny A. Breuer first announced plans to issue “detailed new guidance on the [FCPA’s] criminal and civil enforcement provisions,” the Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) today jointly issued this long-awaited formal guidance entitled A Resource Guide to the U.S. Foreign Corrupt Practices Act (“the Guide”).
Late this summer, press outlets reported on anonymous claims that the Department of Justice and Securities and Exchange Commission likely would be releasing their long awaited FCPA Guidance in advance of an annual OECD Working Group on Bribery meeting on October 10, 2012.