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
Shruti J. Shah
Contributing Editor
Russell A. Stamets
Contributing Editor
Richard Bistrong
Contributing Editor
Eric Carlson
Contributing Editor
Chemical-maker Huntsman Corporation said in an SEC filing last week that the DOJ and SEC won’t take enforcement action against the company for bribes paid in India by employees of a joint venture there.
Have you ever sat across from your joint venture partner in Indonesia. Romania or Taiwan trying to explain why the United States Federal Sentencing Guidelines make it so their employees should be provided with anti-bribery training? I have, and it isn’t a fun conversation.
Part of the European Investment Bank’s Guide to Procurement is the Covenant of Integrity at Annex 3. The EIB requires any company bidding in a project’s procurement process (e.g., for a construction contract or the supply of goods/services) to submit a Covenant of Integrity.
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.
Wojciech Chodan, KBR’s former commercial vice president at a U.K. subsidiary, pleaded guilty today to conspiring to violate FCPA.
Some of the most charming and charismatic people in this world are agents – the middlemen who help foreign companies navigate local waters in return for a slice of revenues, typically around 5%. That may sound like small money, but 5% of $100 million – a little deal for telecommunications, military hardware or energy projects, […]
[…] breaching constructive trust. . . . . The core allegation is that the defendants, without Grynberg’s knowledge, bribed officials in Kazakhstan to win oil rights from joint ventures in which Grynberg had an interest.” Private parties, as we have said, have no right of action under the Foreign Corrupt Practices Act. Only the Department […]
Our most recent post in this series considered compliance programs in the holding company context. In this sixth installment of eight posts on “parental controls,” we turn to more actively managed subsidiaries.
The DOJ said today that Japan’s Marubeni Corporation will pay a $54.6 million criminal penalty to resolve FCPA charges for its role as an agent of the KBR-led TSKJ joint venture.
[…] the FCPA. But it was equally concerned by the Bribery Act and the guidance issued by the Ministry of Justice in relation to the operation of joint ventures. Specifically, they felt that they would be without a defense under the Act if they had done no due diligence prior to entering into the transaction. […]
