Per diems. We in the FCPA bar love to hate them, and with good reason. Who likes the idea of giving cash to foreign officials? If there’s anything that should rankle the anti-corruption specialist, this is it.… Continue Reading
Posts Tagged: Promotional Expenses
California-based SciClone Pharmaceuticals will pay $12.8 million to settle SEC charges that it violated the Foreign Corrupt Practices Act when employees in China pumped up sales for five years by making improper payments to professionals employed at state health institutions.… 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
Avon Products Inc. said in an SEC filing Thursday that the Securities and Exchange Commission offered an FCPA settlement last month with monetary penalties that were ‘significantly greater’ than the $12 million the company had offered.… Continue Reading
Here’s the full FCPA disclosure by Avon Products, Inc. from its Form 10-Q filed with the SEC on November 1:
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We are currently conducting an internal investigation and compliance reviews focused on compliance with the FCPA and related U.S.… Continue Reading
The DOJ’s second Opinion Procedure Release this year approved a plan by 19 non-profit adoption agencies to bring foreign officials to the United States to meet the staff at the agencies and families who have already adopted kids from the officials’ country.… Continue Reading
The U.K. Serious Fraud Office isn’t making any promises to self-reporting companies.
They might still be prosecuted — ‘each case turns on its own facts.’
It was an odd event a few weeks ago when the U.K.’s Serious Fraud Office removed some Bribery Act guidance from its website without explanation.
The deleted guidance dealt with self reporting, corporate hospitality, and facilitating payments.… Continue Reading
FCPA Blog members area, here is Harris Corporation’s full FCPA disclosure from its Form 10-K filed with the SEC on August 27, 2012:
… Continue Reading
As an international company, we are, from time to time, the subject of investigations relating to our international operations, including under the U.S.
Texas-based medical device company Orthofix International N.V. settled FCPA charges today relating to bribes in Mexico.
The company agreed to pay the SEC $5.2 million, including $4.98 million in disgorgement and $242,000 in prejudgment interest.… Continue Reading
Raja Chatterjee, creator and global head of Morgan Stanley’s Anti-Corruption Group, is riding high.