It’s a strange scenario. How did London-based Amec Foster Wheeler (AFW) end up with agents in three different countries for a single, relatively small project in Brazil — including two agents disqualified by AFW’s due diligence and a third agent that AFW thought had lost influence?… Continue Reading
Big pharma Sanofi agreed Tuesday to pay $25.2 million to resolve charges that it paid bribes across the Middle East and in Kazakhstan to win business.
The SEC said Sanofi violated the FCPA’s books and records and internal accounting controls provisions.… Continue Reading
Several articles over the past few days have reported that the DOJ and SEC are quietly revising A Resource Guide to the FCPA, the joint guidance the agencies issued on November 14, 2012, including one article that suggested these revisions occurred as recently as June of this year (see also here and here).… Continue Reading