The DOJ’s charges against Vincente Garcia, the former SAP regional director and head of SAP’s Premier Client Network for Latin America, are filled with advisors, consultants, agents, and channel partners. In the e-mails, they refer to one another as friends and associates, and they talk about their connection with a public official, who at the end of a long transactional road will “owe us a big one.”… Continue Reading
2015 continued the trend of FCPA enforcement actions brought by the SEC with no parallel DOJ enforcement action. As you might expect, these SEC enforcement actions turned on violations of the FCPA accounting provision, either the books and records or the internal controls provisions.… Continue Reading
As reported by the FCPA Blog on Tuesday, infant formula manufacturer Mead Johnson Nutrition Co. entered into a settlement with the SEC, agreeing to pay just over $12 million to resolve allegations that it violated the FCPA’s accounting provisions.… Continue Reading
Mead Johnson Nutrition Co. agreed to pay $12.03 million Tuesday to settle civil charges that it violated the Foreign Corrupt Practices Act.
The SEC said a China unit paid $2 million in bribes to healthcare professionals at state-owned hospitals.… Continue Reading
Infant-formula maker Mead Johnson Nutrition Company disclosed a new FCPA investigation in its latest SEC filing.
It said the SEC had asked for documents about its China unit and “certain expenditures” for product promotions that may have violated the FCPA.… Continue Reading