Harry Cassin
Publisher and Editor
Andy Spalding
Senior Editor
Jessica Tillipman
Senior Editor
Bill Steinman
Senior Editor
Richard L. Cassin
Editor at Large
Elizabeth K. Spahn
Editor Emeritus
Cody Worthington
Contributing Editor
Julie DiMauro
Contributing Editor
Thomas Fox
Contributing Editor
Marc Alain Bohn
Contributing Editor
Bill Waite
Contributing Editor
Russell A. Stamets
Contributing Editor
Richard Bistrong
Contributing Editor
Eric Carlson
Contributing Editor
[…] faces 18 to 24 months in prison under a plea agreement and will forfeit $11 million. He founded and ran Coastal Corporation, which he sold to El Paso Corporation in 2001. In February this year, El Paso settled violations of the U.S. Foreign Corrupt Practices Act related to illegal surcharges it paid to Iraqi […]
[…] been omitted. Here are the current 106 names: 1 ABM Industries Incorporated 2 Accenture PLC 3 Agilent Technologies Inc 4 Airbus Group 5 Alstom SA 6 Analogic Corporation 7 Anheuser-Busch InBev SA/NV 8 AstraZeneca PLC 9 Avon Products Inc 10 Barclays PLC 11 Beam Inc 12 BHP Billiton Ltd 13 Bio-Rad Laboratories Inc 14 […]
[…] the criminal conduct; the number and level of the corporate employees involved; the seriousness, duration, and frequency of the misconduct; and any remedial actions taken by the corporation, including restitution, disciplinary action, and revisions to corporate compliance programs. Prosecutors should also consider the promptness of any disclosure of wrongdoing to the government and the […]
South Korea’s largest telecom company, KT Corporation, paid the SEC $6.3 million Thursday to resolve charges that it violated the Foreign Corrupt Practices Act by providing improper payments to government officials in South Korea and Vietnam. In an internal administrative order, the SEC charged the Seoul-based company with violating the FCPA’s books and records […]
[…] is merely a “paper program” or whether it was designed, implemented, reviewed, and revised, as appropriate, in an effective manner. In addition, prosecutors should determine whether the corporation has provided for a staff sufficient to audit, document, analyze, and utilize the results of the corporation’s compliance efforts. Prosecutors also should determine whether the corporation’s […]
[…] Canada and the UK attribute criminal responsibility to corporations for the misdeeds of individuals working for the corporations. In short, the corporate identification doctrine provides that a corporation may be convicted of a criminal offense, but only when its wrongful acts or intentions are directly attributable to, or the result of the actions of, […]
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.
On March 24, Ball Corporation, an Indiana corporation based in Broomfield Colorado, paid a $300,000 penalty to settle civil FCPA books and records and internal control charges brought by the the SEC.
Job Title: Senior Risk Officer Location: Washington, D.C. Company: International Finance Corporation (IFC) Background / General Description International Finance Corporation (IFC), the private sector arm of the World Bank Group, is a global leader, investor and advisor committed to projects in its developing member countries that reduce extreme poverty and boost shared prosperity. IFC finances private sector […]
[…] an anti-bribery investigation — only one of which considers the existence and effectiveness of the corporation’s pre-existing compliance program. Significantly, this means that under the FCPA, a corporation can still be held criminally and civilly liable for actions by an unknown employee even if it has implemented a comprehensive compliance program — and perhaps […]
