News and commentary about white-collar crime, enforcement, and compliance
Harry Cassin
Publisher and Editor
Andy Spalding
Senior Editor
Jessica Tillipman
Senior Editor
Bill Steinman
Senior Editor
Richard L. Cassin
Editor at Large
Elizabeth K. Spahn
Editor Emeritus
Cody Worthington
Contributing Editor
Julie DiMauro
Contributing Editor
Thomas Fox
Contributing Editor
Marc Alain Bohn
Contributing Editor
Bill Waite
Contributing Editor
Russell A. Stamets
Contributing Editor
Richard Bistrong
Contributing Editor
Eric Carlson
Contributing Editor
It was blockbuster quarter for FCPA enforcement, and April was one of the busiest months on record.
There were five corporate resolutions, including the first-ever double non-prosecution agreements from the DOJ and SEC in the Ralph Lauren case.… Continue Reading
Over the weekend, the German weekly Der Spiegel said the NSA bugged European Union offices in Washington, Brussels, and at the U.N. in New York, and infiltrated EU computers to monitor telephone conversations, e-mails, and other documents.… Continue Reading
In any country, paying for travel for government officials, customers at state-owned enterprises, or customers at purely private enterprises can present corruption risks. Many worthy publications have addressed travel risks generally and how to minimize those risks, including establishing a true business purpose for the trip, ensuring transparency with the recipient’s organization, pre-approving a detailed itinerary to ensure that sightseeing/leisure does not predominate, paying expenses directly to vendors where possible, avoiding unnecessary stopovers or family members or friends accompanying, etc.… Continue Reading
As part of its $398 million settlement Wednesday, Total S.A. agreed with the SEC to disgorge $153 million of profit made from its bribery in Iran. That’s the third biggest disgorgement in FCPA history.… Continue Reading
With its $398 million enforcement action Wednesday, Total S.A. has landed fourth on our list of the Top 10 FCPA cases of all time.
Nine of the biggest cases involve non-U.S.… Continue Reading
Some members of Congress are evidently concerned that corporate defendants are getting off the hook. Too many deferred- and non-prosecution agreements, and not enough criminal indictments.
So acting assistant AG Mythili Raman, who’s now heading the DOJ’s criminal division, testified Wednesday before the U.S.… Continue Reading
Mexico’s state oil giant Petroleos Mexicanos (Pemex) filed a lawsuit in U.S. federal court last week against Siemens and South Korea’s SK Engineering & Construction Co. Ltd. to recover about $160 million in damages caused by their bribery.… Continue Reading
As part of its recent settlement with the SEC, Ralph Lauren Corporation agreed to disgorge $593,000 that was “obtained or retained as a result of the violations discovered during the investigation,” along with $141,846 in pre-judgment interest.… Continue Reading
In a terrific article for Canadian Business called ‘The crackdown,’ John Lorinc says that after decades of turning a blind eye, the Royal Canadian Mounted Police are going after companies that bribe foreigners.… Continue Reading
Acting Assistant Attorney General Mythili Raman of the Justice Department’s Criminal Division Did someone say FCPA enforcement had slowed down? Look again.
Already this month there have been settled enforcement actions involving Philips, Parker Drilling, and Ariel Sharef of Siemens, new charges unsealed against four former BizJet execs with two guilty pleas, and two Alstom execs with one guilty plea, and obstruction charges in a grand jury FCPA investigation.… Continue Reading
Uriel Sharef, a former officer and board member of Siemens AG, settled civil FCPA charges with the SEC Tuesday.
He agreed to pay a $275,000 civil penalty, the second highest penalty assessed against an individual in an FCPA case, the SEC said.… Continue Reading
The Siemens enforcement action is a powerful example of what FCPA enforcement is today . . . and what it is not.
Siemens paid bribes in China, Russia, Venezuela, Mexico, Israel, Bangladesh, Nigeria, and Vietnam. … Continue Reading