Under the FCPA, companies can be punished not only for the wrongful things they do, like paying bribes, but also for certain things they don’t do. In particular, the FCPA’s accounting provisions require companies to have internal controls in place. When companies do not have certain protections, such as appropriate accounting systems and anti-corruption policies, procedures and processes, ...
Monday marked the 126th anniversary of the ending of the the two-day battle of Shiloh. On the second day, the Union troops under General Grant largely recovered the ground that the Confederate troops had taken on the first day. Grant was severely criticized for allegedly being taken by surprise by the Confederate attack, but he managed to survive the ...
As demonstrated below, the sentences handed down in 2013 were a mixed bag, and (except for Frederic Bourke) all individuals cooperated with the government to some extent.
March 10th was the 101st anniversary of the death of Harriet Tubman. She was one of the greatest conductors on the Underground Railroad, which took slaves out of the old south and up to freedom in the north and into Canada. I read about her as a child and her story always moved me.
Foreign Corrupt Practices Act (FCPA) enforcement activity in 2013 was robust, with the DOJ and SEC bringing 31 new FCPA enforcement actions, exceeding 2012’s total of 25.
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 the world of FCPA enforcement, 2013 was a big year. Some have pointed out, “After getting off to a slow start, with no official corporate FCPA settlements announced in the first quarter, 2013 witnessed two of the top 10 biggest settlements of all time.”
Surprisingly, the number of FCPA resolutions that actually involved the Asia-Pacific region sharply declined in 2013, against trend and in apparent contradiction of ubiquitous enforcement attention and coverage.
When James Cole, U.S. Deputy Attorney General, gave his keynote address at ACI’s 30th International Conference on the FCPA, he dedicated an inordinate amount of time to the issue of self disclosures of FCPA violations.