In June 2010, a California-based VOiP company called Veraz Networks, Inc. paid $300,000 to settle SEC charges that it violated the FCPA’s books and records and internal controls provisions by making illegal payments to foreign officials in China and Vietnam.… Continue Reading
Gifts, travel and entertainment, foreign officials, successor liability, and effective compliance programs.
They’re among the topics covered by the new 120-page joint DOJ and SEC guidance on the FCPA.
In the fact sheet accompanying the guidance, the DOJ summarized its position on those topics.… Continue Reading
The DOJ and SEC today released a 120-page FCPA resource guide.
It’s available in pdf here.
The foreword, signed today by the DOJ’s Lanny Breuer and the SEC’s Robert Khuzami, says:
… Continue Reading
The Guide is an unprecedented undertaking by DOJ and SEC to provide the public with detailed information about our FCPA enforcement approach and priorities.
The DOJ agreed last week to end Pride International’s deferred prosecution agreement a year early to reward the company for its enhanced compliance efforts.
The passing of Labor Day marks the advent of a new season. In my new home state of Virginia, the heat has softened and the riverside trees take on a faint yellow; for our friends in the Southern Hemisphere, perhaps the winter wanes and blossoms bud.… Continue Reading
I. Declinations in the News-the Department of Justice responds to many commentators, including this one, and releases it first Declination; laying out the reasons why Morgan Stanley was not prosecuted, when its Managing Director Garth Peterson was, for violating the FCPA.… Continue Reading
Since the Walmart saga became news earlier this week, well-meaning people have been asking the question:
Why do we have the FCPA?
Bribery is a way of life in lots of places, they say.… Continue Reading
Regarding the FCPA Blog’s post Buyers Face Impossible Choice about Opinion Release 08-02, I have to disagree with the conclusion that “Halliburton’s experience was discouraging for anyone with an acquisition program and a desire to comply with the FCPA.”… Continue Reading