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.
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.
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.
FCPA Compliance Attorney Thomas Fox discusses how the Travel Act, which Robert Kennedy urged Congress to enact, is impacting the Foreign Corrupt Practices Act today.
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.
The U.K. Serious Fraud Office announced that it has “reached an agreement with BAE systems that the company will plead guilty” to the offense of “failing to keep reasonably accurate accounting records in relation to its activities in Tanzania.”
A roundup of recent posts by FCPA columnist Mike Koehler, starting with an update on the landmark Africa sting case.
