With GPS, you input a single data point — where you want to go — and the system gives you the information you need to know, exactly when you need to know it.… Continue Reading
Florida-based Harris Corporation said this week it has received a ‘formal order of investigation’ from the SEC relating to the operations of its Carefx subsidiary in China.… Continue Reading
Minnesota-based MTS Systems Corporation said last week that after an investigation of gift-giving, travel, and accommodation practices in its Asia operations, it ‘[removed] certain persons formerly employed in its Korea office.’… Continue Reading
Gift-giving legislation for Brazil can be found in (1) the “Code of Conduct for the Senior Government Officers at the Federal executive branch, Article 9; (2) the Law No. 8429, or “Law of Administrative Probity”, Chapter II, Section I, Article 9, I; and in (3) Decree No 1171, or “Code of Professional Ethics for Civil Servants of the Federal Executive”, Annex, Chapter I, Section III – Prohibitions of Civil Servants, part “g”.… Continue Reading
Under the general topic of graft, school corruption is a well-recognized sub-genre.
Last month, the Criminal Division of the U.S. Department of Justice and the Securities and Exchange Commission published their long-awaited Resource Guide to the U.S. Foreign Corrupt Practices Act.
At 120 pages, this document is intended to assist companies to navigate seemingly arbitrary rules around what does and does not constitute legal behavior when dealing with overseas business practices.… Continue Reading
Last week, the DOJ and SEC issued their long-anticipated Resource Guide regarding the agencies’ FCPA enforcement. Over a year in the drafting, the 120-page Guide addresses, among other things, (1) the definition of a foreign official, (2) gifts and entertainment, and (3) the “hallmarks” of an effective corporate compliance program. … Continue Reading
Here’s what Robert Khuzami said Wednesday at a news briefing about the FCPA guidance released by the DOJ and SEC. Khuzami is head of the SEC’s enforcement division.… Continue Reading
The DOJ and SEC today released a 120-page FCPA resource guide.
It’s available in pdf here.
The foreword, signed today by the DOJ’s Lanny Breuer and the SEC’s Robert Khuzami, says:
… Continue Reading
The Guide is an unprecedented undertaking by DOJ and SEC to provide the public with detailed information about our FCPA enforcement approach and priorities.