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Editors

Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
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

Bill Steinman
Contributing Editor

Why worry about compliance for overseas charitable contributions? Because the Feds do

Last month Amsterdam-based VimpelCom Limited and its wholly owned Uzbek subsidiary, Unitel LLC, paid U.S. penalties of $397.6 million to resolve FCPA offenses.

In its enforcement action, the SEC said that at least $114 million in bribe payments were funneled through an entity affiliated with an Uzbek official, and approximately a half-million dollars in bribes were disguised as charitable donations made to charities directly affiliated with the Uzbek official.   

The head of the SEC’s Enforcement Division observed: “These old-fashioned bribes, hidden through sham contracts and charitable contributions, left the company’s books and records riddled with inaccuracies.”

The VimpelCom settlement is the latest example of FCPA enforcement involving philanthropic activities overseas.… Continue Reading

Practice note: Compliance controls for charitable giving

While clear policies on charitable contributions are important, the controls implementing these policies are equally critical to an effective compliance program.

Which type or types of controls are used in emerging markets is a function of the local level of corruption risk, the nature of the company’s intended contribution, the nature of the company’s business, and the size and complexity of its business.… Continue Reading

Charitable giving: Recognize the warning signs and mitigate the risks

Many individuals, non-profits, and corporations actively support charitable causes around the world. The need to support worthwhile charitable projects in many developing markets is particularly acute due to local needs, the lack of government funding, and the lack of an adequately developed infrastructure.… Continue Reading

VimpelCom reaches $795 million resolution with U.S., Dutch authorities

Amsterdam-based VimpelCom Limited, the world’s sixth-largest telecommunications company, and its wholly owned Uzbek subsidiary, Unitel LLC, entered into resolutions with the DOJ, SEC, and Dutch authorities Thursday for paying more than $114 million in bribes to a government official in Uzbekistan between 2006 and 2012.… Continue Reading

Hyperdynamics resolves FCPA offenses linked to Guinea payments

Hyperdynamics Corporation Tuesday settled alleged FCPA books and records and internal controls offenses by agreeing to pay the SEC $75,000.

The Houston-based oil and gas company received subpoenas from the SEC and DOJ in 2013 requesting documents relating to its business in the African country of Guinea.… Continue Reading

DOJ declination for Hyperdynamics

Hyperdynamics Corporation said Friday the DOJ has closed its FCPA investigation without bringing any charges against the company.

The Houston-based oil and gas company said it had cooperated with the government’s investigation, and the “DOJ noted the value of the Company’s cooperation in its [declination] letter.”

Hyperdynamics received a subpoena from the DOJ in September 2013 requesting documents relating to its business in the African country of Guinea.… Continue Reading