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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
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Elizabeth K. Spahn
Editor Emeritus

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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Russell A. Stamets
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Richard Bistrong
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Eric Carlson
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Posts Tagged: Promotional Expenses

SL Industries’ Gifts and Entertainment Disclosure

From the ‘investigations’ index of ethiXbase, here is SL Industries Inc.’s FCPA disclosure in its latest Form 10-Q filed May 10, 2012.

The New Jersey-based company designs, manufactures, and markets electronics and power protection equipment used in the aerospace, computer, telecom, medical, and transportation industries.… Continue Reading

Avon Discloses SEC Investigation

Avon Products confirmed Thursday that the SEC has issued a formal order of investigation into possible violations of the Foreign Corrupt Practices Act.

Avon’s disclosure appeared in its quarterly report filed with the SEC.… Continue Reading

Scholarship That Rocked The Boat

A few years ago, after a dozen or so enterprising law students asked me what FCPA-related topics were ripe for research, I answered with a post on the FCPA Blog.

My suggestions included: (1) respondeat superior—the legal doctrine imputing to corporate employers the criminal acts of employees; (2) the sad state of the Department of Justice’s Opinion Procedure Releases; and (3) the confusing condition of the FCPA’s promotional-expenses affirmative defense.… Continue Reading

Rockwell Settles China Bribe Case

Rockwell Automation Inc. today settled an administrative proceeding with the SEC for bribes it paid in China.

The company will pay $2.8 million for the settlement, including disgorgement and interest of $2.4 million and a civil penalty of $400,000.… Continue Reading

Life After Guidance: No Change

By Michael Volkov

If you don’t know where you are going, you might wind up someplace else. — Yogi Berra

The U.K. Bribery Act will be effective on July 1 and companies must now decide how to comply.… Continue Reading

IBM Pays $10 Million In SEC Settlement

IBM today resolved civil charges brought by the SEC for violating the books and records and internal control provisions of the Foreign Corrupt Practices Act.

The company admitted making improper cash payments to government officials in South Korea and China, and giving gifts and paying travel and entertainment expenses that violated the FCPA.… Continue Reading

Let’s Keep Talking

On Tuesday, Assistant Attorney General Lanny Breuer, left, acknowledged the growing debate about the FCPA. Although he said the DOJ is listening, his message was loud and clear: When it comes to enforcement, damn the torpedoes, full speed ahead.… Continue Reading

Defending The Defense

By Thomas Fox

I want to thank Kyle Sheahen for his recent post and paper arguing that the promotional expenses defense under the FCPA is illusory. His work has stimulated a useful debate.… Continue Reading