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Tungsten, courtesy of Enough Project via YouTubeAn appellate court Monday struck down part of the conflict-minerals rule, leaving SEC-reporting companies wondering what disclosures to include in their conflict minerals reports due on May 31.
In the prior post, I described recent FCPA enforcement actions — involving Stryker, Polycom, Microsoft, and Juniper Networks — which show that the SEC is on an ‘internal controls rampage’ involving the way issuers (public companies) establish and manage relationships with third parties, particularly distributors and resellers.
For those who missed any of the FCPA enforcement news during the recent hyper-active stretch, here’s what happened: July 28 — Label-maker Avery Dennison Corporation resolved civil and administrative charges brought by the Securities and Exchange Commission. The SEC filed settled enforcement actions in the United States District Court for the Central District of California […]
Label-maker Avery Dennison Corporation, whose compliance problems in China were described in an LA Times story last January, has resolved civil and administrative charges brought by the Securities and Exchange Commission. The SEC filed settled enforcement actions in the United States District Court for the Central District of California charging Avery with violating the FCPA’s […]
The Securities and Exchange Commission said in October this year it is investigating possible violations of the U.S. Foreign Corrupt Practices Act by the leading manufacturers of orthopedic implants. Biomet Inc., Stryker Corp., Zimmer Holdings Inc., Smith & Nephew plc and Medtronic Inc. all made announcements about the SEC’s investigation and denied violating any laws. […]
Shire Pharmaceuticals LLC will pay $56 million to settle allegations that its marketing and promotion of several drugs violated the False Claims Act, the Justice Department said Wednesday.
Click to enlargeAt ACI’s annual FCPA Conference last November, SEC FCPA Unit Chief Kara N. Brockmeyer disclosed that the SEC expects to rely more frequently on administrative proceedings (as opposed to more traditional civil court actions) to resolve FCPA-related enforcement matters.
The SEC’s just-announced investigation of several orthopedic device makers for possible violations of the U.S. Foreign Corrupt Practices Act (reported here) probably originated in February 2007. That’s when Johnson & Johnson said it had “voluntarily disclosed to the U.S. Department of Justice and the U.S. Securities and Exchange Commission that subsidiaries outside the United States […]