3M pays SEC $6.5 million to settle luxury tourism bribes
3M Company agreed Friday to pay the SEC $6.5 million in penalties and disgorgement to resolve FCPA offenses related to a subsidiary in China.… Continue Reading
3M Company agreed Friday to pay the SEC $6.5 million in penalties and disgorgement to resolve FCPA offenses related to a subsidiary in China.… Continue Reading
Through the normal course of research, I review a lot of SEC filings. Over the years, I’ve probably thumbed through more than ten thousand. This has to be the most bizarre SEC filing disclosure related to the FCPA I’ve come across.… Continue Reading
Rio Tinto plc paid the SEC $15 million Monday to settle FCPA offenses related to a consultant hired to retain mining rights in Guinea.… Continue Reading
Influencers have become a major economic force. They can pull in tens of millions of dollars a year while running whole companies dedicated to supporting their efforts. And they’re under pressure to put out increasingly click-worthy content.… Continue Reading
Brazil airline GOL Linhas Aéreas Inteligentes S.A. agreed to pay the DOJ and SEC $41.5 million Thursday to resolve charges that it violated the Foreign Corrupt Practices Act by providing improper payments to officials in Brazil to pass legislation benefitting the company.… Continue Reading
Formula One is an exciting spectacle. Unfathomable speed, exotic locations, and ultra-luxury brands make for a compelling fan experience without mentioning all the behind-the-scenes drama. F1 enthusiasts worldwide come together each race day to cheer on their drivers and teams.… Continue Reading
South Korea’s largest telecom company, KT Corporation, paid the SEC $6.3 million Thursday to resolve charges that it violated the Foreign Corrupt Practices Act by providing improper payments to government officials in South Korea and Vietnam.… Continue Reading
In my practice, I frequently assist clients with risk assessments, program reviews, and developing improvements to their existing anti-bribery and anti-corruption compliance programs, policies and procedures. Based on some recent experience, here is a brief list of key improvements companies can make to their ABAC compliance programs now and the related questions they should be asking as part of that effort.… Continue Reading
Increased regulatory enforcement exposure continues to present directors and officers (D&O) insurance challenges for corporate policyholders. Policies that cover the costly expenses incurred in connection with regulatory investigations, liability payments, and resulting securities litigation are becoming increasingly more difficult and expensive to obtain.… Continue Reading
As a government outsider, it’s impossible to know why there hasn’t yet been any DOJ or SEC corporate enforcement of the FCPA under the current administration. Here are three possible reasons:… Continue Reading
You may have noticed a risk factor in annual reports and SEC registration statements about “conflicting laws and regulations.” Once rare, the warning has become common, thanks to globalized operations and proliferating regulators.… Continue Reading
The SEC has awarded 123 whistleblowers an astounding $731 million since the first payout in 2012. But what do we really know about the whistleblower program? The SEC’s Office of the Whistleblower recently released its 2020 Annual Report to Congress, and it raises more questions than it answers.… Continue Reading