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Editors

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

Mike Scher has his eyes on Delaware

A pending case — largely ignored by the compliance profession and the press — brings before the courts one of the most troubling issues of the Wal-Mart investigation: Was the Wal-Mart Board of Directors misled during 2005-2012 regarding an alleged Mexican bribery scheme and subsequent cover-up?… Continue Reading

Wal-Mart’s December 2013 FCPA disclosure

Here’s what Wal-Mart Stores Inc. said in its quarterly report (Form 10-Q) filed with the SEC on December 6:

 

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The Audit Committee (the “Audit Committee”) of the Board of Directors of the Company, which is composed solely of independent directors, is conducting an internal investigation into, among other things, alleged violations of the U.S.… Continue Reading

Wal-Mart reports on bribery, cover up probe

In its quarterly SEC filing Thursday, Wal-Mart again said it is investigating both alleged FCPA offenses in foreign subsidiaries and ‘whether prior allegations of such violations and/or misconduct were appropriately handled.’… Continue Reading

LyondellBasell investigates Kazakhstan payment

LyondellBasell Industries NV, the Netherlands-based petrochemical maker, made this disclosure in its Form 10-Q filed with the SEC on October 26:

We previously identified an agreement related to a former project in Kazakhstan under which a payment was made that raises compliance concerns under the U.S.

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Avon’s latest FCPA disclosure (November 2012)

Here’s the full FCPA disclosure by Avon Products, Inc. from its Form 10-Q filed with the SEC on November 1:

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We are currently conducting an internal investigation and compliance reviews focused on compliance with the FCPA and related U.S.… Continue Reading

Avon’s latest FCPA disclosure

Photo courtesy of Avon Products Inc.From Avon Products Inc’s Form 10-Q filed with the SEC on August 1, 2012:

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As previously reported, we have engaged outside counsel to conduct an internal investigation and compliance reviews focused on compliance with the Foreign Corrupt Practices Act (‘FCPA’) and related U.S.… Continue Reading

Layne’s Africa Payments Disclosure

From the FCPA Blog members area, here’s the latest FCPA disclosure from water management company Layne Christensen.

The disclosure appeared in the company’s Form 10-Q filed with the SEC on September 10, 2012:

In connection with the Company updating its Foreign Corrupt Practices Act (“FCPA”) policy, questions were raised internally in late September 2010 about, among other things, the legality of certain payments by the Company to agents and other third parties interacting with government officials in certain countries in Africa.

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