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Both the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) announced the agreement by the Dutch company, Snamprogetti Netherlands BV, (Snamprogetti) to pay a $240 million criminal penalty to the DOJ to resolve charges related...
In an article entitled, " Risks and Rewards of an
Independent Investigation " in the October 2010 issue of the ACCDocket , authors James McGrath and David Hildebrandt discuss the use of specialized
outside counsel to lead an independent internal...
Most compliance practitioners are aware of the use of corporate monitors. There are many benefits to the use of a corporate monitor for a company coming out of a lengthy Foreign Corrupt Practices Act (FCPA) investigation. Some of these benefits can include...
In November, 2009 the Organization for Economic and Co-operation and Development (OECD)
announced a new recommendation at the OECD's celebration of "International
Anti-Corruption Day" and the Tenth Anniversary of the " Entry into...
This article concludes our series on what we believe to be
the Top 3 Foreign Corrupt Practices Act (FCPA) cases in the first half of 2010.
We have reviewed the facts surrounding each matter to come up with lessons that
the FCPA compliance professional...
Inspired by our colleague, the FCPA Professor , this post will
pose several questions regarding the Foreign Corrupt Practices Act (FCPA) in
connection with one of the most Byzantine litigation matters of current renown,
that being Chevron's legal...
At most Foreign Corrupt
Practices Act (FCPA) compliance and ethics training sessions there is usually
one or more archetypal story about "someone I know" who was solicited to pay a
bribe or "I heard about someone" from whom a bribe...
enforcement of the Foreign Corrupt Practices Act (FCPA) be suspended for those
US companies now working in Haiti? This topic has been in discussion for a few
weeks. It began with a statement by Wall Street Journal editorial board member
We were recently introduced to Fraud Examiner Expert Tracy Coenen , in her
book " Expert Fraud Investigation: A Step-By-Step Guide " she details the
steps a company should go through in performing a fraud investigation. Coenen
The baseball season is upon us and the Houston Astros
have opened with their worst start since 1983. At 3-9, things may be looking a
bit bleak for the hometown heroes. However several sportswriters have pointed
out that the 1983 team ended up with...
At its April 7,
2010 meeting the United States Sentencing Commission approved amendments to its
Sentencing Guidelines . The next
day on April 8, 2010, the UK Bribery
Bill received Royal Assent. These two events follow the December 9, 2009
Many Foreign Corrupt Practices Act (FPCA) and UK Bribery
Act practitioners are well aware of the oratory of the US and UK governments on
the evils of bribery and corruption. However, such a fight is not just being
made by the US Department of Justice...
We have previously blogged on the various stages
of the relationship that a US company would travel through
with a Foreign Business Partner, from the pre-relationship due diligence to the
post-contract execution management. (See Here ,
There is an ongoing debate in the compliance arena as to
whom a Chief Compliance Officer (CCO) should report. Should the CCO report to
the Board of Directors or appropriate Board committee such as an Audit
Committee or Compliance Committee? Or can...
SEC enforcement this week
brought another SOX claw back case, as well as actions alleging financial fraud
and another investment fund case. DOJ dropped their appeals in the two Broadcom
criminal option backdating cases which were dismissed for prosecutorial...