As we approach the anniversary of the Financial Conduct Authority’s first published set of aggregated results, it’s a good time to review what that means for risk managers across the UK and Europe.… Continue Reading
A new report recently published by The Ethics and Compliance Initiative (ECI), the 2019 Global Business Ethics Survey, addresses the state of E&C programs across ten countries — USA, Brazil, UK, Spain, France, Italy, Germany, Russia, India, and China.… 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 million penalty to the SEC, plus pre-judgment interest of $1.3 million.
Juniper first disclosed the FCPA-related investigation in an SEC filing in August 2013.… Continue Reading
Deutsche Bank paid the SEC $16 million Thursday to settle FCPA offenses related to its hiring of relatives of public officials in China and Russia.
The German bank disgorged $10.7 million and paid a $3 million penalty to the SEC, plus pre-judgment interest of $2.4 million.
Deutsche Bank first disclosed the FCPA-related investigation in an SEC filing in March 2015.… Continue Reading
Enforcement actions by U.S. and European enforcement agencies as well as the World Bank have drawn attention to bribery offenses committed by multinational companies in Russia and other former Soviet republics, in particular in Central Asia.… Continue Reading
The U.S. Treasury Department’s Office of Foreign Assets Control Thursday imposed sanctions on five individuals, including at least three Russians, and on a Chechen group for extra-judicial killings and torturing LGBT individuals.… Continue Reading
On March 21, the Russian general prosecutor’s office published the official year-end statistics for corporate bribery enforcement in 2018, which are once again aimed at demonstrating the country’s tough stance on fighting corruption.… Continue Reading
A UK court recently concluded that even when there’s ample evidence demonstrating connections to another state, UK courts may nonetheless affirm their own jurisdiction, if there are at least some connections providing a basis to do so.… Continue Reading
Russian telecom MTS joined our Top Ten list last week at number three. It knocked Och-Ziff off the list, and that means nine of the ten biggest FCPA cases of all time now involve non-U.S.… Continue Reading
Corporate investigations in Russia are conducted in a heavily regulated environment. They are further complicated by numerous practical challenges. Observing the legal and factual requirements is like navigating through a minefield.… Continue Reading
As previously reported, Russia recently amended its corporate bribery statute (Article 19.28 of the Code of Administrative Violations) to allow companies to avoid prosecution if they assist in the discovery or investigation of the offense or if they can prove that the bribe was extorted.
The same amendment also allowed courts to preliminarily freeze the property of companies under investigation up to the maximum amount of the fine.
On December 27, President Putin signed another amendment to 19.28 which will, this time, significantly expand the scope of corporate liability for bribery.… Continue Reading
Due diligence in Russia has never been simple. Two recent developments make it more complicated. One makes business more transparent.… Continue Reading