Last April, the DOJ’s Criminal Division launched the one-year Pilot Program. The remaining four months of the Pilot Program promise to provide valuable information on several fronts.
In the prior post I talked about how, after nearly 40 years of FCPA history, the DOJ first used disgorgement as a remedy, including it this year in two declinations under the Pilot Program.… Continue Reading
This year the DOJ required disgorgement of ill-gotten gains as a predicate for preferential treatment under the new FCPA enforcement Pilot Program, regardless of whether the participating company was publicly or privately owned. … Continue Reading
Last week’s $264 million enforcement action against JPMorgan Chase included disgorgement to the SEC of $130.5 million — the seventh biggest FCPA disgorgement of all time.
The SEC said $105.5 million was disgorgement and $25 million was pre-judgment interest.… Continue Reading
Texas-based Lennox International Inc. said in a securities filing Monday that it self reported to the SEC and DOJ an alleged payment of $475 to a Russian customs broker or official.… Continue Reading
The Justice Department released letters Thursday under the DOJ’s Pilot Program to two Texas companies that won’t be prosecuted for violating the FCPA but will each have to disgorge all profits they made from the bribery.… Continue Reading
Networking giant Cisco Systems Inc. said in its annual report Thursday that following an investigation into operations in Russia and some CIS countries, the DOJ and SEC won’t bring FCPA enforcement actions.… Continue Reading
During the second calendar quarter, there were four corporate FCPA enforcement actions and eight individual resolutions (seven related to Direct Access Partners). There were also three guilty pleas by individuals.
Akamai Technologies and Nortek Inc.… Continue Reading
After Nortek and Akamai resolved FCPA enforcement actions with the SEC Tuesday with non-prosecution agreements requiring cooperation and disgorgement, both companies released declination letters issued under the DOJ’s new Pilot Program.… Continue Reading
The Securities and Exchange Commission Tuesday announced non-prosecution agreements (NPAs) with two unrelated companies for bribes foreign subsidiaries paid to Chinese officials.
Massachusetts-based internet services provider Akamai Technologies agreed to pay about $652,000 in disgorgement and about $19,400 in interest. … Continue Reading
Key Energy Services Inc. said Thursday the Justice Department informed the company that it has closed its FCPA investigation and won’t bring an enforcement action.