Corporate

Recent Posts

Looking Back on the Eckhardt Amendment
Posted on 21 Mar 2013 by Mike Koehler

This article was reprinted with permission from FCPA Professor Yesterday's post ( here ) highlighted the FCPA's first mega-enforcement action involving multiple actors. The story remained open as to George McLean (Vice President of Solar... Read More

Stranger than Fiction: Questions in the FCPA World
Posted on 18 Aug 2011 by Thomas Fox

I had intended to post Part II of my series the recent court rulings on instrumentalities. However, sometimes events overtake you. In the world of the Foreign Corrupt Practices Act (FCPA), some of the fact scenarios are so preposterous that if they... Read More

Friday FCPA Roundup for Week Ending June 13
Posted on 13 Jun 2014 by Mike Koehler

This article was reprinted with permission from FCPA Professor Elevate your FCPA knowledge and practical skills, FCPA ripples, origins of PetroTiger’s FCPA scrutiny, news flash, and for the reading stack. It’s all here in the Friday Roundup... Read More

Analyzing the DOJ’s Recent “Foreign Official” Enforcement Theory
Posted on 15 Sep 2015 by Mike Koehler

This article was reprinted with permission from FCPA Professor In the recently announced Foreign Corrupt Practices Act enforcement action against Daren Condrey (see here for the prior post), the DOJ advanced an extremely broad “foreign official”... Read More

Louis Berger International and Two Former Employees Resolve Enforcement Action
Posted on 21 Jul 2015 by Mike Koehler

This article was reprinted with permission from FCPA Professor Last Friday, the DOJ announced the second corporate Foreign Corrupt Practices Act enforcement action of 2015. It was against Louis Berger International Inc. (LBI, a New Jersey-based... Read More

Friday FCPA Roundup for Week Ending June 20
Posted on 20 Jun 2014 by Mike Koehler

This article was reprinted with permission from FCPA Professor Scrutiny alerts, across the pond, for the reading stack, and congrats. It’s all here in the Friday Roundup. Scrutiny Alerts And Updates The Wall Street Journal reports here... Read More

Revisiting a Foreign Corrupt Practices Act Compliance Defense
Posted on 12 Sep 2012 by Mike Koehler

reprinted with permission from Mike Koehler , Southern Illinois University School of Law 2012 Wisconsin Law Review 609 Abstract: This article asserts that the current FCPA enforcement environment does not adequately recognize a company's... Read More

The Weatherford FCPA Settlement, Part II
Posted on 5 Dec 2013 by Thomas Fox

Earlier, I reviewed the Weatherford International Limited (Weatherford) Foreign Corrupt Practices Act (FCPA) settlement. Today I will take a more focused look at the bribery schemes involved and the failure of the company to bring internal controls up... Read More

Friday FCPA Roundup for Week Ending July 26
Posted on 26 Jul 2013 by Mike Koehler

This article was reprinted with permission from FCPA Professor A sign-off, no surprise, scrutiny alert, for the reading stack, spot-on, and the $10 million man. Judge Leon Signs-Off On IBM Action As highlighted in this prior post, in March 2011... Read More

SEC Enforcement Trends 2011: The New Era of FCPA Enforcement
Posted on 14 Apr 2011 by Thomas O. Gorman

Spurred on by a very positive report on its enforcement efforts by the OCED, the Department of Justice has declared that this is a "new era" of FCPA enforcement. The result is more cases, a continuous stream of record breaking amounts paid... Read More

Issues To Consider From The Smith & Wesson FCPA Action
Posted on 31 Jul 2014 by Mike Koehler

This article was reprinted with permission from FCPA Professor This post highlights various issues to consider from this week’s Smith & Wesson Foreign Corrupt Practices Act enforcement action . Should There Be a Difference? If the U... Read More

Miss Marple Short Stories and SEC Enforcement of the FCPA, Part I
Posted on 16 Mar 2015 by Thomas Fox

I am a huge Agatha Christie fan. I have read most of the Poriot novels and many of the Jane Marple novels as well. However, I was not aware of Christie’s work in the short story format until I recently read a volume entitled Miss Marple Short Stories... Read More

Friday FCPA Roundup for Week Ending July 31
Posted on 31 Jul 2015 by Mike Koehler

This article was reprinted with permission from FCPA Professor Scrutiny alerts, noisy exit, double standard, quotable and for the reading stack. It’s all here in the Friday roundup. Scrutiny Alerts FIFA-Related As predicted in this May... Read More

Best Practices During an FCPA Enforcement Action: The Armor Holdings NPA
Posted on 14 Jul 2011 by Thomas Fox

As reported by the FCPA Blog , Corruption Currents in the Wall Street Journal and numerous others , on July 13, 2011, Armor Holdings Inc., entered into a Non-Prosecution Agreement (NPA) with the Department of Justice (DOJ) to pay a $10.29 million... Read More

Duke’s Season of Failures
Posted on 8 Apr 2015 by Mike Koehler

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... Read More