Bill Steinman recently wrote a post for the FCPA Blog about compliance risks in offset obligations. I’d like to continue that discussion, this time with some information about international cooperation to clean up offset transactions, and how the U.S. Internal Revenue Service is playing a role.
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[…] Pilot Program since it launched in April 2016. The most recent one was in June this year involving CDM Smith Inc. The Pilot Program gives companies incentives to self-disclose FCPA violations, and to cooperate, remediate, and disgorge. Companies that qualify can receive a 50 percent discount on fines they might face under the U.S. […]
The White House announced on May 8 that the United States would pull out of the Joint Comprehensive Plan of Action (JCPOA) and reinstate sanctions on Iran to address that country’s nuclear program.
A federal appeals court ruled Friday that a non-resident foreign national cannot be charged with conspiracy to violate the Foreign Corrupt Practices Act or with aiding and abetting a violation of the FCPA, unless the government can show that he acted as an agent of a “domestic concern” or while physically present in the […]
The UK Serious Fraud Office said three former FH Bertling Group senior executives and a ConocoPhillips employee were convicted Tuesday for their role in a bribes-for-contracts plot.
[…] to 61 individual whistleblowers since its first award in 2012. Awards are paid out of penalties the SEC collects from securities law violators. Whistleblowers can be eligible for an award when they voluntarily provide the SEC with “original, timely, and credible information” that leads to a successful enforcement action. Awards can range from 10 […]
Just because a country has a law — or a company has a compliance system, for that matter — it doesn’t automatically mean it works or is put to work. And so it is with countries’ anti-money laundering and counter financing of terrorism (AML/CFT) systems, in which this year’s Basel AML Index has recorded […]
[…] administrations. 2019 also saw a number of other remarkable trends. We continued to see the ascendancy of the SEC in corporate resolutions. While this has been building for a number of years now, the SEC in 2019 used the FCPA’s internal controls provision to stake out some rather aggressive positions — positions that I […]
Eva Joly, a Norwegian-born former French magistrate, is running for the French presidency under the Green Party banner. She became famous across Europe for being a fearless anti-corruption campaigner, even taking on former minister Bernard Tapie and Crédit Lyonnais bank. Her best-known case involved French oil giant Elf Aquitaine. She uncovered fraud leading to […]