In the prior post, I described recent FCPA enforcement actions — involving Stryker, Polycom, Microsoft, and Juniper Networks — which show that the SEC is on an ‘internal controls rampage’ involving the way issuers (public companies) establish and manage relationships with third parties, particularly distributors and resellers.… Continue Reading
Over the last two years, the Securities and Exchange Commission has set its sights on distributor and reseller relationships, and excoriated companies that failed to adequately manage and supervise them. The focus on these third-party relationships is part of the agency’s broader application of the FCPA’s internal controls provision in an increasingly aggressive manner.… Continue Reading
Last year, we saw more enforcement actions brought against individuals than ever (up to 34, depending on how you’re counting), and a record number of convictions secured after trial (three). The cost of violating the FCPA continued to skyrocket.… Continue Reading
In this era of heightened FCPA enforcement, it is easy to assume that a red flag signals the end of a relationship with a business intermediary. By my count, 11 of the last 17 FCPA enforcement actions involved bribes funneled to foreign officials through third parties.… Continue Reading
Juniper Networks paid the SEC $11.7 million Thursday to settle FCPA offenses related to its sales practices in Russia and China.
The American technology company disgorged $4 million and paid a $6.5… Continue Reading