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Chamber of Commerce: Corporations Form the Cornerstone of FCPA Compliance

Recently one of the most unlikely sources for praise of the Foreign Corrupt Practices Act (FCPA) came out to inform us all that corporations are the cornerstone of FCPA compliance and enforcement. You may be surprised to find out that it came from the US Chamber of Commerce. It did not come in the form...

And The Apples Go To …

This article was reprinted with permission from FCPA Professor Often times there seems to be an echo chamber when it comes to Foreign Corrupt Practices Act reporting, commentary, etc. One such occasion has been the recent Layne Christensen enforcement action (see here for the prior post). The theme...

FCPA Survey Results From the Classroom

This article was reprinted with permission from FCPA Professor Call them green, inexperienced, and naive as to how things really work. I call them good Foreign Corrupt Practices Act survey respondents because they are immersed in learning: (i) about black letter legal principles; (ii) legal authority...

Friday FCPA Roundup for Week Ending December 5

This article was reprinted with permission from FCPA Professor Transparency International’s latest Corruption Perception Index, monitor issues, scrutiny alert, Chinese SOEs, SEC press releases, hot, and for the reading stack. It’s all here in the Friday roundup. Transparency International’s...

The Alstom FCPA Enforcement Action – Part I

As the first blog post of 2015, I thought it appropriate to highlight two outstanding confluences. The first is that this year is the centenary of the birth of Orson Welles. While not occurring in 2015, near the end of 2014 we had the settlement of the long-standing Alstom Foreign Corrupt Practices Act...

Friday FCPA Roundup for Week Ending January 9

This article was reprinted with permission from FCPA Professor From the dockets, cleared, when the dust settles, outreach, and quotable. It’s all here in the Friday roundup. From the Dockets Sigelman This recent post highlighted the motion to dismiss filed by Joseph Sigelman. Among...

Friday FCPA Roundup for Week Ending January 16

This article was reprinted with permission from FCPA Professor Hollywood film studios, more FBI agents, asset recovery, quotable, and for the reading stack. It’s all here in the Friday roundup. Hollywood Film Studios A recent Wall Street Journal article went in-depth regarding the FCPA...

Friday FCPA Roundup for Week Ending January 30

This article was reprinted with permission from FCPA Professor Scrutiny alerts, compliance defense, be a scholar, industry news, and for the reading stack. It’s all here in the Friday roundup. Scrutiny Alerts The Bank of New York Mellon Corp (BNY Mellon) recently disclosed : “In...

Friday FCPA Roundup for Week Ending February 6

This article was reprinted with permission from FCPA Professor Quotable, on offense, scrutiny alert, to FCPA Inc., and resource alert. It’s all here in the Friday roundup. Quotable This article in The Recorder reports on a recent public event in which Assistant Attorney General Leslie...

Friday FCPA Roundup for Week Ending February 13

This article was reprinted with permission from FCPA Professor Scrutiny alert and for the reading stack. It’s all here in the Friday roundup. Scrutiny Alert In August 2012, the Israel-based Teva Pharmaceuticals first disclosed its FCPA scrutiny and in its most recent annual report the...

Friday FCPA Roundup for Week Ending February 20

This article was reprinted with permission from FCPA Professor Wal-Mart related, north of the border, scrutiny alerts and updates, and an issue to watch. It’s all here in the Friday roundup. Wal-Mart Related Here is what Wal-Mart said in its recent 4Q FY2015 earnings call . “FCPA...

SNC-Lavalin Should Be Grateful and Not Pout

This article was reprinted with permission from FCPA Professor But Mom / Dad, when Johnny gets into trouble his parents do things a little bit differently, why can’t I benefit from that? As I told The Globe and Mail in this article, that is my reaction to SNC-Lavalin’s unusual statement...

Goodyear to Pay SEC More Than $16M to Settle Federal Corruption Claims

WASHINGTON, D.C. — (Mealey’s) According to the terms of administrative order issued by the Securities and Exchange Commission today, Goodyear Tire & Rubber Co. will pay more than $16 million to settle claims that it violated provisions of the Foreign Corrupt Practices Act (FCPA) by failing...

Without Admitting or Denying the SEC’s Findings, Goodyear Resolves SEC Administrative Action

This article was reprinted with permission from FCPA Professor As highlighted in this previous post, in February 2012 Goodyear Tire & Rubber Company disclosed as follows. “In June 2011, an anonymous source reported, through our confidential ethics hotline, that our majority-owned joint...

Goodyear Settles SEC FCPA Charges

Goodyear Tire and Rubber Company settled FCPA books and records and internal control charges with the SEC. The settlement reflects the extensive cooperation and remedial efforts of the company. In the Matter of Goodyear Tire and Rubber Company, Adm. Proc. File No. 3-16400 (February 24, 2015). The...

Issues to Consider From the Goodyear Enforcement Action

This article was reprinted with permission from FCPA Professor This recent post highlighted the SEC FCPA enforcement action against Goodyear. This post continues the analysis by highlighting various issues to consider associated with the enforcement action. Invoking a Standard That Does Not...

Friday FCPA Roundup for Week Ending February 27

This article was reprinted with permission from FCPA Professor Save the date, scrutiny updates, coming attraction, job alert, and for the reading stack. It’s all here in the Friday roundup. Save the Date An event notice for East Coast readers. On Friday, March 6th, the Fordham Law Review...

Can You Spot the FCPA Risk?

This article was reprinted with permission from FCPA Professor A high-ranking government official encourages other governments to sign deals and change policies to the advantage of various companies. At the same time, those companies were among the many that gave to the high-ranking official’s...

Minnie Minoso Broke Barriers; Goodyear Pushes Compliance Forward

Yesterday we celebrated the hard-nosed playing style of Anthony Mason, who recently passed away. Today we honor a true pioneer in professional baseball, Minnie Minoso, or Mr. White Sox. Minoso was the first black Cuban to play in Major League Baseball (MLB) when he debuted for the Cleveland Indians in...

Ingots of Gold & SEC FCPA Enforcement – Communication – Part IV

Today I want to use the Agatha Christie’s story Ingots of Gold as an introduction to some of the regular communications that the Securities and Exchange Commission (SEC) representatives frequently provide in public forums, regarding their views on Foreign Corrupt Practices Act (FCPA) enforcement...

Friday FCPA Roundup for Week Ending April 3

This article was reprinted with permission from FCPA Professor Looking for talent – got talent, FBI announcement, Bourke related, to FCPA Inc., and for the reading stack. It’s all here in the Friday Roundup. Looking for FCPA Talent? Got Talent If your firm or organization is looking...

Duke’s Season of Failures

This article was reprinted with permission from FCPA Professor Earlier this week, Duke won the national championship basketball game to cap off a successful season. By one measure, Duke was thus the most successful team in college basketball this year. However, it is undisputed that Duke failed...

Friday FCPA Roundup for Week Ending April 10

This article was reprinted with permission from FCPA Professor Making a difference, to FCPA Inc., and scrutiny alert. It’s all here in the Friday roundup. Making a Difference In running this website, I sometimes feel like the captain of a small ship on a wide vast ocean. My metrics tell...

Wal-Mart Three Years Later

This article was reprinted with permission from FCPA Professor Three years ago this week, the New York Times ran a major story ( here ) titled “Vast Mexico Bribery Case Hushed Up by Wal-Mart After Top-Level Struggle.” The conduct at issue in the Times article related to Wal-Mart’s...

Friday FCPA Roundup for Week Ending April 24

This article was reprinted with permission from FCPA Professor Really no big deal, scrutiny alerts, across the pond, quotable, and for your viewing pleasure. It’s all here in the Friday roundup. Really No Big Deal Lockheed’s request (which the SEC does not oppose) to be relieved...