In the past two years, the cost of compliance failures – as measured by the imposition of “mega fines,” by which we mean federal corporate criminal fines of $350 million or more – has increased dramatically.
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.
This past week, Pfizer announced that it would pay a $1.2 billion criminal fine as part of a $2.3 billion settlement involving illegal off-label drug promotion. The facts of the Pfizer case will be closely studied by pharma compliance personnel for various lessons learned specific to the industry, but there are also general compliance lessons to be learned.
The Justice Department is stepping up enforcement of the FCPA, with over 120 FCPA investigations currently underway including Sun Microsystems and Royal Dutch Shell. Siemens AG was recently punished with a hefty fine for FCPA violations.
By Thomas Fox — FCPA Compliance Attorney
The year 2009 is shaping up to be a watershed year in Foreign Corrupt Practices Act (FCPA) compliance investigations and enforcements. This article will review the current state of FCPA investigations and enforcement actions and provide guidance to companies to help navigate in this time of heightened FCPA sensitivity.
There is plenty of bad news out there about Halliburton and KBR. The most recent was released yesterday, when an independent electrical inspector reported bad electrical wiring on U.S. bases in Iraq. KBR has been sued for soldier’s electrocution death.
The litany of allegations and fines against Halliburton continued this week as the company agreed to pay a record $559 million fine as part of a settlement for charges that a Haliburton subsidiary, KBR Inc., bribed Nigerian officials during a gas deal.
