In May, a month after it agreed to be acquired by Oracle for $7.4 billion, Sun Microsystems said it may have violated the Foreign Corrupt Practices Act and that the violations could have a material effect on its business. It launched an internal investigation and shared the results with the Justice Department and the Securities […]
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A January 19, 2008 report in the German business magazine WirtschaftsWoche (here) says unnamed members of Siemens’ supervisory board (equivalent to U.S. directors) think the company may be fined as much as €4 billion by United States regulators for alleged violations of the Foreign Corrupt Practices Act. The magazine reports that the supervisors are basing […]
Job Title: Compliance Officer
Company: Bilfinger SE
Location: Mannheim, Germany
The Compliance Officer will lead efforts to promote compliance at all levels of Bilfinger and contribute to the continuous improvement of the compliance program and the underlying elements. She/he will support the business to implement and apply compliance-related policies, controls and procedures. The position holder will report to the Chief Compliance Officer and will be part of the global Compliance Leadership Team.
Marcelo Odebrecht (Image courtesy of the Economist via YouTube)Brazilian police arrested Marcelo Odebrecht, the billionaire CEO of the powerful Odebrecht conglomerate.
Following yesterday’s post, several readers suggested that we mention any other FCPA-related cases, appeals, sentencings and enforcement actions during the past year involving individuals. It’s a good idea, and our thanks go out to Marc and our other correspondents. _______________ Our post Kozeny’s Co-Defendant Wins Appeal (September 1, 2008) discusses Victor Kozeny, Frederic Bourke and […]
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.
Here are the top ten FCPA settlements of all time. If our math is right, the financial penalties (criminal fines, civil disgorgement, and prejudgment interest) add up to $2.8 billion, with almost 50% of that coming from the top two settlements. Five of the top six involve non-U.S. companies. The oldest case on the list […]