Since August 2012, there has been a lot of discussion in anti-corruption circles about Oracle’s settlement with the SEC, including here. Much of the past discussion has focused on the fact that the SEC charged Oracle with books & records and internal controls FCPA violations without an attendant allegation of bribery.… Continue Reading
We considered in a prior post the new spirit of tough enforcement at the DOJ and SEC and the need to seize the opportunity for more advocacy by the compliance profession, in particular to head off a resolution of the Wal-Mart investigation harmful to compliance officers and the public.… Continue Reading
The Securities and Exchange Commission Wednesday charged husband-and-wife executives and their China-based company with FCPA books and records and internal controls violations in a non-bribery case. The couple allegedly overstated the company’s revenues and diverted proceeds from a securities offering for their personal use.… Continue Reading
The Securities and Exchange Commission on Tuesday released its final administrative order against Dutch electronics firm Koninklijke Philips Electronics N.V. reflecting an out-of-court settlement of FCPA-related allegations.
Philips agreed to pay $4.5… Continue Reading
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.… Continue Reading
Courtesy of the members area of the FCPA Blog, here’s the full FCPA disclosure by Central European Distribution Corp. from its Form 10K/A filed with the SEC on October 5:
… Continue Reading
It has also been determined that there has been a breach of the books and records provisions of the Foreign Corrupt Practices Act (FCPA) of the United States and potentially other breaches of the FCPA.
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
The SEC on Friday (September 28) filed a partially-settled civil injunctive action in federal court in Minnesota against Subramanian Krishnan, the former CFO of Digi International, Inc., alleging multiple offenses under the books and records and internal controls provisions of the FCPA.… Continue Reading