FCPA enforcement report for Q3 2020
Harry Cassin
October 1, 2020
During the third calendar quarter, there were three corporate FCPA enforcement actions with penalties and disgorgement totaling about $182.7 million.… Continue Reading
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
Wisconsin marketing firm pays $10 million to resolve FCPA offenses
Richard L. Cassin
September 27, 2019
Quad/Graphics Inc. agreed Thursday to pay the SEC nearly $10 million to settle violations of the Foreign Corrupt Practices Act for long-running bribery schemes and cover-ups in Peru and China.
The Sussex, Wisconsin print and digital marketing company disgorged $6.9 million and prejudgment interest of about $960,000, and agreed to pay a civil penalty of $2 million.… Continue Reading
Polycom reaches $16 million FCPA settlement for China bribes
Harry Cassin
December 26, 2018
American communication technology provider Polycom Inc. settled FCPA books and records and internal accounting controls provisions charges with the SEC Wednesday for using resellers and distributors in China to bribe government officials. … Continue Reading
ING wins SEC declination after $900 million Dutch penalty
Harry Cassin
September 5, 2018
The SEC closed its investigation into ING Group NV one day after the banking giant reached a $900 million settlement with Dutch authorities.
In a new SEC filing Wednesday, ING said:
As previously noted, in connection with the investigations ING also received information requests from the U.S.… Continue Reading
DOJ declination for UK engineering firm
Richard L. Cassin
August 22, 2018
The Justice Department said Monday it won’t prosecute a UK engineering firm for possible FCPA and money-laundering violations.
Guralp Systems Limited or GSL, based in Reading, UK, received the declination letter (pdf) “notwithstanding evidence of violations of the FCPA.”… Continue Reading
DOJ: Don’t let FCPA enforcement fears stop M&A deals
Richard L. Cassin
July 26, 2018
Deputy Assistant Attorney General Matthew MinerThe prosecutor who oversees the criminal division’s FCPA unit said the DOJ wants corporate acquisitions to happen and doesn’t want the “specter of enforcement to be a risk factor that impedes such activity by good actors.”… Continue Reading
Juniper Networks lands DOJ declination
Richard L. Cassin
February 12, 2018
Juniper Networks, Inc. said an SEC filing Friday that the DOJ has closed its FCPA investigation of the company and won’t bring an enforcement action.
The SEC’s investigation is still pending, Juniper said.… Continue Reading
Bill Steinman: What’s new about the DOJ’s new FCPA corporate enforcement policy?
Bill Steinman
December 1, 2017
FCPA practitioners welcomed Rod Rosenstein’s announcement that the Department of Justice has made the FCPA Pilot Program permanent, and incorporated it into the U.S. Attorneys’ Manual. In the words of one of my colleagues, the audience “noticeably lightened up” at the Deputy AG’s news. … Continue Reading
Double declination ends Net1 FCPA probe
Richard L. Cassin
July 31, 2017
Net 1 UEPS Technologies said in a securities filing Thursday that the DOJ has closed its investigation of possible violations of the Foreign Corrupt Practices Act.
The DOJ investigation had apparently continued since the company received an SEC declination (pdf) in mid 2015 for the same matter.… Continue Reading
World Bank sanctions (but doesn’t debar) CDM Smith for non-compliance in Vietnam
Richard L. Cassin
July 5, 2017
The Boston engineering company that paid $4 million last week to settle FCPA offenses in India was also sanctioned by the World Bank Thursday for failing to disclose a subcontract on a project in Vietnam.… Continue Reading
Boston contractor pays $4 million for declination with disgorgement
Richard L. Cassin
June 30, 2017
Privately held CDM Smith Inc. entered into a declination with disgorgement Thursday with the Justice Department to resolve FCPA offenses in India.
The DOJ said employees and agents of CDM Smith and a wholly owned subsidiary in India paid $1.18 million in bribes to government officials.… Continue Reading
Linde pays $11 million for declination with disgorgement
Richard L. Cassin
June 20, 2017
Two American units of Germany’s Linde Group received a declination with disgorgement from the DOJ Friday for FCPA offenses in the Republic of Georgia.
Under the declination pursuant to the FCPA Pilot Program, Linde North America Inc.… Continue Reading