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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

Posts Tagged: Disclosure

CEDC’s FCPA Disclosure

Courtesy of the members area of the FCPA Blog, here’s the full FCPA disclosure by Central European Distribution Corp. from its Form 10K/A filed with the SEC on October 5:

It has also been determined that there has been a breach of the books and records provisions of the Foreign Corrupt Practices Act (FCPA) of the United States and potentially other breaches of the FCPA.

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Layne’s Africa Payments Disclosure

From the FCPA Blog members area, here’s the latest FCPA disclosure from water management company Layne Christensen.

The disclosure appeared in the company’s Form 10-Q filed with the SEC on September 10, 2012:

In connection with the Company updating its Foreign Corrupt Practices Act (“FCPA”) policy, questions were raised internally in late September 2010 about, among other things, the legality of certain payments by the Company to agents and other third parties interacting with government officials in certain countries in Africa.

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ABM Industries’ Latest FCPA Disclosure

Building services company ABM Industries Incorporated said it has spent ‘$3.3 million of legal fees and other costs associated with an internal investigation into a foreign entity previously affiliated with a joint venture.’… Continue Reading

Nordion Discloses Investigation

Ontario, Canada-based Nordion Inc. disclosed Wednesday in a Form 6-K (Report of Foreign Private Issuer) filed with the SEC that it’s investigating a foreign supplier and other third parties for potential FCPA and Canadian law compliance issues.… Continue Reading

Facilitating Payments And The Reporting Dilemma

Compliance insider Pete from DC first appeared on this blog nearly five years ago.

We’re happy to report that he still drops by.

In response to yesterday’s Small (Bribe) Talk From The Editors, Pete sent this comment:

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Dear Editors:

Fascinating discussion, and I think Marc Alain Bohn’s point about transparent recording deserves a bit more attention, as it puts public companies (i.e.,… Continue Reading