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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

Posts Tagged: Disclosure

Hewlett-Packard’s latest FCPA disclosure (March 2014)

Here’s the full FCPA disclosure from HP’s Form 10-K filed with the SEC on March 11, 2014:

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The German Public Prosecutor’s Office (“German PPO”) has been conducting an investigation into allegations that current and former employees of HP engaged in bribery, embezzlement and tax evasion relating to a transaction between Hewlett-Packard ISE GmbH in Germany, a former subsidiary of HP, and the General Prosecutor’s Office of the Russian Federation.

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Wal-Mart’s December 2013 FCPA disclosure

Here’s what Wal-Mart Stores Inc. said in its quarterly report (Form 10-Q) filed with the SEC on December 6:

 

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The Audit Committee (the “Audit Committee”) of the Board of Directors of the Company, which is composed solely of independent directors, is conducting an internal investigation into, among other things, alleged violations of the U.S.… Continue Reading

SEC logged 3,238 whistleblower tips this year

Whistleblower tips and complaints increased to 3,238 in 2013, up from 3,001 in 2012, the SEC’s Office of the Whistleblower said in its annual report to Congress. There were 149 FCPA tips in fiscal year 2013, up from 115 in 2012. … Continue Reading

Why no alarm bells back home over SEC Gold Fields probe?

Listing shares internationally often carries unwelcome regulatory and compliance risks. This was recently highlighted by the SFO’s corruption probe into the London-listed Kazakh miner ENRC, shortly to be delisted, as well as probes into Indonesia miner and London-listed Bumi plc, and most recently by the SEC’s investigation of South Africa’s Gold Fields, which has a secondary New York listing.… Continue Reading

Disclosure can be too much of a good thing

From SEC Commissioner Daniel M. Gallagher’s remarks at the 67th National Conference of the Society of Corporate Secretaries & Governance Professionals, Seattle, Washington on July 11, 2013:

The vital importance and proven value of our disclosure regime as a whole does not and should not lead to the conclusion that more government-mandated disclosure is always better.… Continue Reading

Can we relax yet?

Professor Peter J. Henning of Wayne State University Law School (Photo courtesy of Wayne Law)Over the last decade, since the passage of the Sarbanes-Oxley Act in 2002, publicly traded corporations have poured significant resources into their compliance programs to prevent wrongdoing, or to at least be an early warning system for what might become a problem.… Continue Reading