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
Modern compliance solutions are about actionable information. Like an in-vehicle GPS, they’re incomparably more powerful than a fold out map.
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
MTS Systems Corporation said it has investigated possible violations of the FCPA and in January ‘presented the results of its investigation and its corrective actions to representatives of the Department of Justice and the SEC.’… Continue Reading
Image courtesy of Harris CorporationFlorida-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.
In Vietnam, where schoolhouse bribery is ‘an open secret,’ twenty-two teachers and staff recently received written warnings at the Hanoi University of Agriculture.… Continue Reading
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
Both the new guidance and recent remarks by officials make clear that, although the FCPA has no value threshold, the government is not interested in bringing cases over de minimis payments to foreign officials.… 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
Robert Khuzami of the United States Securities and Exchange CommissionHere’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
Just over a year after Assistant Attorney General Lanny A. Breuer first announced plans to issue “detailed new guidance on the [FCPA’s] criminal and civil enforcement provisions,” the Department of Justice (“DOJ”) and the U.S.… 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 ReadingThe Guide is an unprecedented undertaking by DOJ and SEC to provide the public with detailed information about our FCPA enforcement approach and priorities.
