The only U.S.-headquartered company now on the FCPA top ten list is KBR (and its former parent, Halliburton). It landed second after paying $579 million in 2009 to settle an enforcement action for its role in the so-called TSKJ Nigeria consortium.… Continue Reading
Hobbies are important and we try to make time for ours — staring at the list of the biggest FCPA cases of all time.
Stare long enough, we’re convinced, and you can learn most of what’s important about FCPA compliance and enforcement.… Continue Reading
Houston-based KBR said in an SEC filing this week that its compliance monitor ‘has certified that KBR’s current anti-corruption compliance program is appropriately designed and implemented to ensure compliance with the FCPA and other applicable anti-corruption laws.’… Continue Reading
Oil field services giant Halliburton said this week its internal investigations into potential FCPA and conflict violations in Angola and Iraq are continuing, and the company is reporting all results to the DOJ and SEC.… Continue Reading
From the FCPA Blog members area, here’s Halliburton Co.’s FCPA disclosure in its SEC filing on October 23:
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We are conducting internal investigations of certain areas of our operations in Angola and Iraq, focusing on compliance with certain company policies, including our Code of Business Conduct (COBC), and the FCPA and other applicable laws.
The blogs spoke loudly in an article by Leslie Wayne in the New York Times that recently highlighted FCPA enforcement against foreign companies.
Taking a page from our top ten list, Wayne said:
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The companies that have reached the biggest settlements under the law, known as the Foreign Corrupt Practices Act, include Siemens, the German engineering giant; Daimler, the maker of Mercedes-Benz vehicles; Alcatel-Lucent, the French telecommunications company; and the JGC Corporation, a Japanese consulting company.
Regarding the FCPA Blog’s post Buyers Face Impossible Choice about Opinion Release 08-02, I have to disagree with the conclusion that “Halliburton’s experience was discouraging for anyone with an acquisition program and a desire to comply with the FCPA.”… Continue Reading