Many companies have an investigation protocol in place when a potential Foreign Corruption Practices Act (FCPA) or other legal issue arises. However, many Boards do not have the same rigor when it comes to an investigation, which should be conducted or led by the Board itself.
I admit it took me awhile to finally get it. I have long wondered what could have caused the explosion in DOJ and SEC enforcement of the Foreign Corrupt Practices Act (FCPA).
In honor of the return of Sherlock to PBS with Season 3, I begin a week of Sherlockian-themed posts. Today we consider the quality of justice that Holmes discussed in The Abbey Grange…
The FCPA isn’t the only anti-corruption law. More than 70 countries have statutes against bribery or corrupting government officials. Tune into the next installment of Tom Fox’s FCPA training series…
SEC and DOJ look at the facts and circumstances around each case in making assessments. While this is frustrating to business types, as a lawyer I find it to be an appropriate analysis, — and an accurate way to look at things.
Last week marked the anniversary of the birth of one of the most notorious Americans of all time: Benedict Arnold. His name is synonymous with the word traitor in the United States and in many ways more derogatory.
One of the more public and ongoing corruption scandals in the world right now seems to be happening in Turkey. To say the events and facts are confused is an understatement.
Last week, it was announced that the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) had settled an enforcement action with Archer-Daniels-Midland Company (ADM).
I cannot think of any criminal enforcement actions against a corporation involving the Foreign Corrupt Practices Act (FCPA) where there was a lone wolf employee engaging in bribery and corruption on his or her own.
In late November, Weatherford International Limited (Weatherford) concluded one of the longest running open Foreign Corrupt Practices Act (FCPA) investigations when it agreed to the ninth-largest FCPA fine of all-time and one of its subsidiaries, Weatherford Services Limited …