In this era of heightened FCPA enforcement, it is easy to assume that a red flag signals the end of a relationship with a business intermediary. By my count, 11 of the last 17 FCPA enforcement actions involved bribes funneled to foreign officials through third parties.… Continue Reading
A new report recently published by The Ethics and Compliance Initiative (ECI), the 2019 Global Business Ethics Survey, addresses the state of E&C programs across ten countries — USA, Brazil, UK, Spain, France, Italy, Germany, Russia, India, and China.… Continue Reading
TechnipFMC plc paid the SEC $5 million Monday to settle FCPA offenses related to bribing Iraqi officials to win business with state-owned oil companies.
The London-headquartered oil and gas company disgorged $4.3 million plus pre-judgment interest of $735,000 to the SEC.
In a recent speech, the Chairman of the SEC argued that other countries’ failure to enforce foreign anti-bribery and corruption laws may put U.S. companies at a competitive disadvantage to foreign firms.… Continue Reading
Imagine your house is on fire. In the front of the house, you have a fire department working tirelessly to put out the fire with water. In the back, someone is spraying your house with gasoline.*
Such is the current state of U.S.… Continue Reading
It is no secret that the global commodities trading sector is rife with corruption risks. We at Global Witness have been investigating this for years, and have seen enforcement efforts fall short all too often.… Continue Reading
The U.S. Department of Justice recently published new guidance on how it will assess corporate compliance programs. The DOJ Guidance streamlines previous U.S. guidance and expands on key subjects; providing a greater insight into how the the DOJ will approach its evaluation of compliance programs when considering whether a prosecution or other resolution is appropriate.
By comparison, the UK Bribery Act 2010 Guidance, which came out in 2011, contains six principles which “commercial organizations” undertaking part of their business in the UK must adhere to if they are to have a defense to a charge of failing to prevent bribery.… Continue Reading
As whistleblower protection continues to grow as an important part of the compliance landscape worldwide, companies should be prepared for the inevitable increase in incidents requiring investigation. This includes allegations of corruption and bribery, which can present significant challenges when raised through internal whistleblower channels.… Continue Reading
The UK Serious Fraud Office said Friday it has closed bribery investigations into UK-based GlaxoSmithKline PLC and individuals at subsidiaries of Rolls-Royce Holdings PLC.
SFO director Lisa Osofsky said in a statement there was “either insufficient evidence to provide a realistic prospect of conviction or it is not in the public interest to bring a prosecution in these cases.”
In a response filed with the London Stock Exchange, GSK said it was “pleased that the SFO have closed their investigation and concluded that no further action is required.”
In 2016, London-based GSK paid the U.S.… Continue Reading
The DOJ said Tuesday that a Hawaii-based businessman admitted bribing officials from Micronesia.