In one of his latest posts, Mike Koehler discusses the reasons why many companies will voluntary disclose information to the SEC that is only a potential FCPA violation.
DynCorp Fires Executive Counsel and Chief Compliance Officer Curtis Schehr
November 30, 2009
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”.
A Bribery Scheme Hatched at the “Eggs Benedict Place”
November 24, 2009
The DOJ announced today that John Joseph O’Shea was recently arrested for his alleged role in a conspiracy to bribe Mexican foreign officials to secure contracts with the Comision Federal de Electridad, an apparent Mexican state-owned utility company. In addition to charging conspiracy to violate the FCPA, the indictment contains twelve substantive FCPA charges (among other charges).
FCPA Roundup: Another Speech, Lighthouses and Buoys, and an FCPA Triangle
November 18, 2009
Mike Koehler’s latest FCPA contribution is a roundup of recent posts from his FCPA Professor blog. Among the titles: “Another FCPA Speech”, “Of Course It’s Because of the Oil”, “Jefferson Sentenced / When a Jury Verdict is Relegated to a Footnote”, “Lighthouses and Buoys”, “An FCPA Triangle”.
Critical FCPA and Export Compliance Issues for the Health Care Industry
November 16, 2009
Eric McClafferty, export compliance and international trade regulation partner at Kelley Drye & Warren LLP, examines important FCPA compliance and export compliance keys for health industry companies.
The Interesting FCPA Investigations Regarding Blackwater and Morgan Stanley
November 12, 2009
Blackwater (and its executives) could be in some murky FCPA water in connection with alleged secret payments to Iraqi officials. Also, Garth Peterson was fired by Morgan Stanley last December over concerns that he may have violated the FCPA.
Complex FCPA Case Concludes with 366 Day Sentence for Frederic Bourke
November 11, 2009
Yesterday, in one of the most complex FCPA cases in history, Judge Shira Scheindin (S.D.N.Y.) sentenced Frederic Bourke to 366 days in federal prison (followed by three years probation) and ordered him to pay $1 million fine.
Risk-Based Compliance: A Framework for Analysis
November 9, 2009
by Thomas Fox, FCPA Compliance Attorney
In order to assess any risk a company must have a framework in place to begin this analysis. The benefits of a risk-based compliance system are clear. To make this risk-based determination, a company must institute a structure to make an appropriate assessment.
The Energy Security Through Transparency Act of 2009 (S. 1700)…A Bad Bill
November 3, 2009
By Michael Koehler, CCI Featured FCPA Columnist
The Energy Security Through Transparency Act of 2009 (S. 1700), while however noble its intended purpose, is akin to “swatting a fly with a bazooka.”
Sun Cites “Increased Regulatory Complexity and Corporate Compliance Requirements” For Extensive Partner Information Request
October 29, 2009
Some Canadian partners of Sun Microsystems were angered and surprised recently by an extensive, and purportedly invasive, request for information that is part of Sun’s renewed due diligence focus on overseas internal activities.
