Instead of our regular post today, these familiar and fitting words:
No man is an Island, entire of itself; every man is a piece of the Continent, a part of the main; if a clod be washed away by the sea, Europe is the less, as well as if a promontory were, as well as if a manor of thy friends or of thine own were; any man’s death diminishes me, because I am involved in Mankind; And therefore never send to know for whom the bell tolls; It tolls for thee.… Continue Reading
The FCPA Blog is produced and edited by attorneys of Cassin Law LLC. The firm helps clients comply with United States laws, including the Foreign Corrupt Practices Act.
The information in The FCPA Blog is intended for public discussion and educational purposes only.… Continue Reading
Perhaps the biggest, although not yet the loudest, international corruption story involves Siemens AG, the German electronics and electrical engineering giant. Siemens says it has identified “a multitude of payments made in connection with [consulting agreements] for which we have not yet been able either to establish a valid business purpose or to clearly identify the recipient.… Continue Reading
Its jurisdictional reach is legendary, but understanding exactly why the FCPA’s coverage stretches so far and wide is not always easy. One explanation comes from the United States Attorneys’ Manual, in this clear and sometimes ominous exposition:
… Continue Reading
Under the FCPA, U.S.
Textron Inc., without admitting or denying books and records and internal controls allegations, consented to the entry of a final judgment with the SEC permanently enjoining it from future violations of Sections 13(b)(2)(A) and 13(b)(2)(B) of the Securities Exchange Act of 1934, ordering it to disgorge $2,284,579 in profits, plus $450,461.68… Continue Reading
“There are moral problems as well as legal problems that go far beyond simply the question of illegal payoffs to foreign officials.
“There are questions concerning the role of multinational corporations, the extent to which they have obligations to the countries in which they conduct their business, the extent to which they should seek to raise the standards of conduct there, the respect which they should show the laws of other countries.… Continue Reading