Last week’s $1.06 billion blockbuster resolution by Sweden’s Ericsson included disgorgement to the SEC of $540 million. By our count that’s the second biggest disgorgement ever ordered in an FCPA enforcement action.… Continue Reading
Swedish telecom Ericsson agreed Friday to pay the DOJ and SEC over $1 billion in one of the biggest Foreign Corrupt Practices Act enforcement actions ever.… Continue Reading
The Securities and Exchange Commission said Monday the CEO of Collectors Café used settlement agreements with aggrieved investors that illegally prohibited them from complaining to authorities about alleged fraud.… Continue Reading
Last month’s $231 million FCPA resolution by German dialysis giant Fresenius Medical Care included disgorgement to the SEC of $147 million. By our count, that’s the tenth biggest disgorgement ever ordered in an FCPA enforcement action.… Continue Reading
Petrobras’s $1.78 billion FCPA resolution last week included disgorgement of $933.5 million, the biggest ever ordered in an FCPA enforcement action.
The SEC allowed Petrobras to credit against the disgorgement the money it had already paid into a settlement fund for U.S.… Continue Reading
Telia Company AB’s $965.6 million settlement Thursday included disgorgement to the SEC of $457 million, the biggest disgorgement ever ordered in an FCPA enforcement action.
Telia won’t actually pay the SEC $457 million in dsgorgement, however.… Continue Reading
The SEC said in an enforcement order Thursday that Sweden’s Telia Company AB will disgorge $457 million to resolve FCPA violations in Uzbekistan.
Combined with $548.6 million in criminal penalties against the company reflected Thursday in court filings by the DOJ, less a $40 million offset, Telia will pay $965 million for the settlement.… Continue Reading
We’ll spend a number of posts this month explaining what is good about the Pilot Program and what may be better. The last post explained the four (not three) requirements the Program establishes — voluntary disclosure, cooperation, remediation, and disgorgement — and how some of those terms have been carefully (re)defined.… Continue Reading
There have been seven declinations under the DOJ’s Pilot Program since it launched in April 2016. The most recent one was in June this year involving CDM Smith Inc.
The Pilot Program gives companies incentives to self-disclose FCPA violations, and to cooperate, remediate, and disgorge.… Continue Reading
As readers of the FCPA Blog are aware, the Pilot Program requires voluntary self-disclosure and cooperation with the government in order to be eligible for a declination from the DOJ.
Since the Pilot Program’s inception, three public companies have disgorged profits to the Securities and Exchange Commission in return for a declination from the DOJ.… Continue Reading