Mark Mendelsohn (DOJ Deputy Chief, Fraud Section and the DOJ’s FCPA “top cop”) recently defended the 2008 Siemens enforcement action. This post takes issue with Mendelsohn’s defense of the Siemens enforcement action.
Mike Koehler discusses the recent release by the OECD of “the most comprehensive guidance ever provided to companies and business organizations by an international organization” on internal controls, ethics and compliance programs to combat bribery.
It was reported this weekend that Daniel Alvirez, the President of ALS Technologies, Inc., is expected to plead guilty to charges of conspiracy to violate the FCPA set forth in a superseding indictment and cooperate in the government’s investigation.
On March 22nd, the Georgetown Journal of International Law will be hosting a symposium titled “Combating Global Corruption”. Panelists include a collection of FCPA practitioners, industry representatives, academics and enforcement officials.
The FCPA Professor analyzes the latest developments in the BAE case, which include the “bribery yet bribery” case leaving the U.S. and heading across the pond to the U.K.
Today’s post includes FCPA excerpts from various speeches/comments made by enforcement officials over the past couple of days. Stepping to the podium will be Assistant Attorney General Lanny Breuer; Mark Mendelsohn – Deputy Chief of the DOJ Fraud Section; and Cheryl Scarboro – the head of the SEC’s newly formed FCPA unit.
The folks at Innospec Inc. may be wishing it sold things like fighter jets in places like Saudi Arabia than what it actually sells – things like Tetraethyl Lead in places like Indonesia. When bribery and corruption take place in the former instance, there is no exposure for bribery and corruption (see here), but when it takes place in the latter instance, there is exposure for bribery and corruption.
The seemingly minor case involving Telecommunications D’Haiti (“Haiti Teleco”) keeps on giving. The recent plea by Jean Fourcand is the most recent news in a case in which the DOJ has cast a wide net.
Both the antibribery provisions and the books and records and internal control provisions of the FCPA apply to issuers. That was easy. What is not so easy is figuring out just which companies are issuers.
While respectful of the obvious human dimension of this case, the Africa Sting case could not have come at a better time for FCPA practitioners, which tend to be employed by large law firms – although not exclusively.
