This is the second installment of our three part series on the Top 3 Foreign Corrupt Practices Act (FCPA) matters of 2010 to date and their significance for the FCPA compliance professional. Today, we turn our attention to the Avon bribery scandal in China.
Alcatel-Lucent recently disclosed it had reached agreements with the DOJ and SEC to resolve bribery and corruption allegations in several countries, including Costa Rica, Taiwan, and Kenya.
Voluntary disclosure of potential FCPA violations is a tricky issue, made even more difficult given the potential conflict of interest FCPA counsel has in advising the company as to the important disclosure issue, particularly where the disclosure only involves a potential FCPA violation.
Curtis Schehr was fired by DynCorp International, reports August Cole of the Wall Street Journal. According to Cole, Schehr, who had been DynCorp’s Chief Compliance Officer and Executive Counsel, as well as a Senior V.P., was fired “without cause”.
Mike Koehler, CCI’s FCPA featured columnist, has a few interesting new pieces to share.
We have posted his most recent work, regarding Iraq and what constitutes and FCPA violation, herein. Additionally, links to his other recent posts are included after the article.
The third FCPA trial of the summer has concluded and Los Angeles area film executives Gerald and Patricia Green have been found guilty by a federal jury of conspiracy to violate the FCPA, substantive FCPA violations, and other charges.
Although most (72 percent) business professionals expect an increase in Foreign Corrupt Practices Act (FCPA) violations in the next two years, one-third (34 percent) of organizations still have no comprehensive FCPA compliance program in place, according to a recent Deloitte webcast poll.
In the latest CCI featured article, Sharie Brown, chair of FCPA and Corporate Compliance at DLA Piper, provides a list of “red flags” companies can instruct their employees to watch out for to manage compliance risk of overseas operations. Red flags are included for the areas of anti-bribery, export controls, anti-money laundering, anti-terrorism, and anti-boycott risks.
Mike Koehler is the new Featured FCPA Columnist for CCI. In his first contribution, Koehler discusses benchmarking FCPA compliance and the risk of FCPA violations even in seemingly low-risk countries.
Another company has felt the burn of FCPA violations. This time the company is Nature’s Sunshine, which was recently fined by the SEC for bribing Brazilian officials and failing to provide proper disclosure.
