Harry Cassin
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Richard L. Cassin
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Cody Worthington
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Julie DiMauro
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Thomas Fox
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Marc Alain Bohn
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Bill Waite
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Shruti J. Shah
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Russell A. Stamets
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Richard Bistrong
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Eric Carlson
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So far this year, two FCPA enforcement actions have involved companies that resolved previous FCPA violations. With Tenaris in June, and Oracle this week, the number of FCPA recidivists rises to 15.… Continue Reading
Compliance officers are now a power center in many organizations with far reaching influence, oversight, and access to sensitive information. Employee records, investigation documents, sensitive legal findings, and communications with governments could all be valuable information for bad actors to acquire for espionage or profit.… Continue Reading
IBM said in an SEC filing that the DOJ and SEC have closed their FCPA investigations into transactions in Argentina, Bangladesh, Poland, and Ukraine.
The U.S. investigations started in early 2012 when IBM notified the SEC of a probe by the Polish Central Anti-Corruption Bureau.… Continue Reading
Let’s recap. In my first post, I examined a limited set of circumstances where I believe it is reasonable under the FCPA to pay per diems to foreign officials.
In my second post, I looked at the enforcement agencies’ take on per diems by analyzing the FCPA Resource Guide as well as the Opinion Procedure Releases where the DOJ found it appropriate to make cash payments to foreign officials.… Continue Reading
United States Circuit Judge Sri SrinivasanA three-judge federal appeals court said Tuesday the DOJ’s settlement with Fokker Services B.V. for alleged sanctions violations could go ahead after a district court judge rejected the arrangement as “anemic.”… Continue Reading
Police in Canada arrested seven people, including officials of IBM and its local partner, along with employees of Quebec’s tax agency for alleged corruption in connection with a $24 million contract.… Continue Reading
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Click to enlargeAt 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
DOJ and SEC enforcement of the FCPA slowed a bit during the summer months. But after a blockbuster Q2, the third quarter still saw four guilty pleas, one more than the prior quarter, and three declinations, up from two in the previous three months.… Continue Reading
Representatives of over 30 firms were gathered in a small Beijing hotel last month to receive a stern message from the National Development and Reform Commission (NDRC) division chief, Xu Xinyu.… Continue Reading
Wal-Mart is the largest retail organization on the planet. Indeed its nickname among financial analysts is “Planet Wal-Mart.” Repeatedly ranked Number One on the Fortune 500 list, Wal-Mart has more revenue than Apple, IBM, Microsoft, Amazon and Pepsi – COMBINED.… Continue Reading
After a wait of two years, a federal judge Wednesday granted final approval for IBM’s settlement with the SEC of civil FCPA charges.
U.S. District Judge Richard Leon, left, OK’d the $10 million settlement he first rejected in March 2011.… Continue Reading
In any country, paying for travel for government officials, customers at state-owned enterprises, or customers at purely private enterprises can present corruption risks. Many worthy publications have addressed travel risks generally and how to minimize those risks, including establishing a true business purpose for the trip, ensuring transparency with the recipient’s organization, pre-approving a detailed itinerary to ensure that sightseeing/leisure does not predominate, paying expenses directly to vendors where possible, avoiding unnecessary stopovers or family members or friends accompanying, etc.… Continue Reading
