Another FCPA Action With No Monitor

fcpa

Another week, another FCPA enforcement action against a Swiss commodities trader — and one that again might leave compliance officers puzzled, since it involves a repeat corporate offender that didn’t self-disclose, yet still managed to walk away without a compliance monitor. The company in question is Trafigura, which last week pleaded guilty to charges that…

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Swiss Trader Gunvor Pays $661M on FCPA Fails

gunvor

Our latest FCPA enforcement action is a $661 million monster against Swiss trading firm Gunvor, which has pleaded guilty to bribing Ecuadorian government officials through the 2010s in exchange for intelligence about upcoming business contracts with the state-owned oil company of Ecuador. The Justice Department announced the settlement last Friday, along with a companion settlement…

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SAP Pays $220M on FCPA Violations

SAP

German software giant SAP is paying $220 million and implementing a raft of reforms to settle FCPA violations in seven countries, in a case with lessons about the importance of internal audits to root out misconduct and about structural reforms regulators want to see to prevent repeat offenses.  The Justice Department and Securities and Exchange…

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Lessons in Freepoint FCPA Settlement

fcpa

Federal authorities served up a $98 million FCPA enforcement action at the end of last week against a commodities trading firm in Connecticut. Today let’s take a look at the details of that case to see what the firm did and what lessons the rest of the compliance world can learn. The company in question…

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Some Vague Hints on Analytics, FCPA

fcpa

The Justice Department is stepping up its own use of data analytics to identify instances of corporate misconduct, and will boost its cooperation with overseas law enforcement to bring more anti-corruption cases as well, a senior department official said this week. The remarks came from Nicole Argentieri, acting assistant attorney general for the Criminal Division,…

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Two New FCPA Settlements

fcpa

Compliance officers have two new FCPA settlements to read over Thanksgiving break, including an intriguing hint that perhaps the Justice Department is taking a slightly more expansive view of its policy for chief compliance officers certifying the effectiveness of their compliance programs.  The companies in question are Tysers Insurance Brokers Ltd. and H.W. Wood Ltd.,…

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That Clear Channel FCPA Settlement

Clear Channel

Before the moment slips by, we should take a look at that FCPA enforcement action against Clear Channel Outdoor Holdings that the Securities and Exchange Commission announced two weeks ago. The more you read the details, the more you wince at this tale of poorly managed executives and ineffective internal auditing. Don’t let this stuff…

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Breaking Down 3M’s FCPA Case

3M

Manufacturing giant 3M Corp. is our latest addition to the annals of FCPA enforcement, agreeing last week to pay $6.5 million to resolve civil charges from the Securities and Exchange Commission that the company’s China subsidiary wined and dined government officials with tourism junkets. By now it’s an old story to compliance professionals: U.S. company…

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Snoozer of an FCPA Settlement

fcpa

I don’t know about the rest of you, but I spent the long weekend very much relaxed and far from the news. So let’s ease back into the workweek with the most pipsqueak FCPA enforcement action the compliance community has seen in a long while.  At least, I think it’s pipsqueak. Read the breakdown of…

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Philips Settles FCPA Case With SEC

fcpa

Manufacturing giant Philips has agreed to pay $62 million to settle FCPA charges with the Securities and Exchange Commission, for a rather ho-hum corruption scheme in China that compliance officers have seen many times before. The case is still interesting, however, because this is Philips’ second FCPA settlement in 10 years. That raises the question…

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