The DOJ and SEC have prosecuted 240 different companies (by my count) for FCPA offenses. Of those 240 companies, 13 have been repeat FCPA defendants. That means the recidivism rate for all corporate FCPA defendants is about 5.5 percent.… Continue Reading
Posts Tagged: Halliburton
Last month, the Commodity Futures Trading Commission ordered JPMorgan Chase & Company and its subsidiaries to pay a total of $920.2 million for artificially manipulating market prices of precious metals by sending false signals to other market participants.… Continue Reading
Construction firms have been at the center of many enforcement actions under the Foreign Corrupt Practices Act, including some of the biggest FCPA cases ever. Why is the construction industry so vulnerable, and how can companies protect themselves and their employees?… Continue Reading
Halliburton’s recent decision to enter into a $29.2 million settlement with the SEC over alleged FCPA violations in Angola illustrates the challenges faced by corporate compliance officers in designing and implementing an effective FCPA compliance program.… Continue Reading
Halliburton Company paid the SEC $29.2 million in disgorgement and penalties Thursday for violating the FCPA’s books and records and internal accounting controls provisions.
The SEC said Halliburton gave business to a friend of an Angolan official.… Continue Reading
On March 29, two senior UK judges dismissed an attempt by Unaoil to challenge an SFO investigation into allegations that the company paid bribes around the world. It is the latest in a fast-growing list of failed judicial reviews against the SFO brought on shaky legal grounds.… Continue Reading
This could be the first year since 2005 when the DOJ won’t issue any FCPA Opinion Procedure Releases.
There have never been a lot FCPA releases — just 61 since 1980, an average of less than two per year.… Continue Reading
The Securities and Exchange Commission announced its first enforcement action Wednesday against a company for using restrictive language in confidentiality agreements that could illegally stifle whistleblowing.
The SEC charged Houston-based KBR Inc.… Continue Reading
The current list of the ten biggest FCPA cases includes only two U.S.-based companies — KBR at number three and Alcoa at number six. The rest are non-U.S. companies.
In the DOJ’s second FCPA opinion procedure release of the year, the agency restated some important boundaries around successor liability.
Successor liability makes an acquiring company responsible for criminal acts of the acquired company before the acquisition.… Continue Reading
At ACI’s annual FCPA Conference last November, SEC FCPA Unit Chief Kara N. Brockmeyer disclosed that the SEC expects to rely more frequently on administrative proceedings (as opposed to more traditional civil court actions) to resolve FCPA-related enforcement matters.… Continue Reading
Kellogg Brown & Root LLC, Technip S.A., and JGC Corp. agreed to pay $17 million in penalties in a settlement with the African Development Bank (ADB) for corrupt practices by affiliated companies in connection with contracts for liquefied natural gas production plants on Bonny Island, Nigeria from 1995 until 2004.… Continue Reading