FCPA

Attorneys Benjamin Britz and Sean Mason unwrap Supreme Court Justice Samuel Alito’s fishy defense of a lavish, billionaire-funded trip. For international anti-corruption lawyers and compliance professionals trained by years of vigorous enforcement activity, American domestic political practices can seem surreal.  What is criminal abroad may be acceptable, even constitutionally protected, here.  Recent revelations that Supreme Court Justice Samuel Alito accepted...

Unpacking SEC's enforcement action against Philips for FCPA allegations in China Credit Where Credit's Due? Philips FCPA Enforcement Action What’s in this whitepaper by Tom Fox:Amsterdam-based Philips recently agreed to pay more than $62 million to resolve the SEC's charges that it violated the FCPA with conduct related to the sale of medical diagnostic equipment in China. Not only is...

Navigating pitfalls of doing business in risk-filled region

The year that was in FCPA & anti-corruption efforts 2022: A Year in Review FCPA Enforcement & Anti-Corruption Developments What’s in this report from Paul, Weiss:After a quiet 2021, FCPA enforcement, whether measured by the number of DOJ and SEC corporate enforcement actions or total penalty amount, increased markedly in 2022, although it still fell somewhat below pre-2021 levels on...

Go inside Honeywell's profit-sharing/bribery scheme Profit Sharing as Bribery The Honeywell FCPA Enforcement Action What’s in this report from podcaster and compliance expert Tom Fox:Honeywell International’s U.S.-based subsidiary settled an FCPA enforcement action with the DOJ and SEC, coughing up criminal penalties of about $79 million. Podcaster and FCPA expert Tom Fox digs into the particulars of the case, including:...

Companies accused of corporate crimes will have more incentives to disclose misconduct they uncover and cooperate with federal investigations, Assistant Attorney General Kenneth Polite Jr. said Tuesday. In remarks at Georgetown University’s law school, Polite seemed to soften the Biden Administration’s corporate criminal enforcement stance and offer more carrots in the government’s “carrot-and-stick” policies in the form of fewer prosecutions...

Find out how a three-time convicted FCPA violator, ABB, managed to avoid having a monitorship imposed. A Win for Compliance ABB FCPA Resolution What’s in this whitepaper from Tom Fox:Tom Fox digs into the recently announced DOJ resolution with Swiss construction company ABB over accusations that it violated the FCPA. Simple enough, right? Maybe not so much, as a closer...

Keep up with FCPA enforcement, including actions against a commodity trader, a tech firm and a steel manufacturer. Hughes, Hubbard & Reed FCPA & Anti-Bribery Fall 2022 Alert What’s in this whitepaper from Hughes, Hubbard & Reed attorneys:Hughes, Hubbard & Reed attorneys take a comprehensive view of the most important global anti-bribery cases and recent FCPA enforcement actions, exploring how...

Use of third-party apps, executive compensation need attention sooner rather than later

Breaking down the FCPA allegations against technology company Oracle Corp. Unpacking Oracle FCPA Enforcement Action Oracle: FCPA Recidivist What’s in this whitepaper from Tom Fox:For the second time, Oracle Corp., the Austin-based technology giant, has run afoul of provisions of the FCPA, according to the SEC. The agency has ordered the company to pay more than $23 million to resolve...

FCPA opinion releases can form part of your compliance program guidance arsenal, but there have only been two of them in the past seven years, so if you are relatively new to ethics and compliance, you may not be so familiar with them. In this month’s column, Mary Shirley covers some of the basics about FCPA opinion releases, offering takeaways...

Tom Fox dives into the details of Stericycle’s multinational bribery scheme in Latin America that landed the company millions of dollars in fines. The cultural corruption was so deeply embedded that Stericycle was essentially forced to shut down a large part of its Latin American business, according to government documents. In this whitepaper, Fox explores the background of the case...