Double Blast of FCPA News

fcpa

Keep up, compliance officers! A subsidiary of global consulting giant McKinsey agreed today to pay $122.8 million to settle FCPA charges in South Africa; and the Justice Department says it might allow some companies currently under corporate integrity agreements to exit those agreements early.  Those are very different news stories, so we’ll take each one…

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Betting/Bitcoin Biz Settles FCPA Charges

fcpa

Federal prosecutors have sanctioned a one-time Chinese online lottery business turned bitcoin mining operation for violations of the Foreign Corrupt Practices Act, where senior executives bribed Japanese lawmakers in the late 2010s to win permissions to open a casino there — and good lord, writing that sentence feels like hitting some sort of corruption risk…

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Telefónica Pays $85M on FCPA Fails

Telefónica

The Latin American telecom giant Telefónica settled FCPA charges late last week, paying $85 million and reminding everyone that at least for now (and possibly for a good long while yet), the world of corporate compliance and FCPA enforcement continues to turn. Let’s take a look at the lessons we can learn here. The Justice…

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Moog Dinged on FCPA Violations

Moog

The Securities and Exchange Commission served up a rather hum-drum FCPA enforcement action last week. While the case certainly isn’t a show-stopper, it does offer compliance professionals a few insights about corporate corruption; so let’s fulfill our due diligence obligations and study it. The company is Moog Inc., maker of motion controls systems for aerospace,…

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Lessons From Deere FCPA Sanction

Deere

Deere & Co. is paying $10 million to settle one of the more colorful FCPA cases we’ve seen in a while, replete with Thai massage parlors, envelopes of cash, sketchy overseas agents — and even a few lessons about compliance fundamentals from due diligence of acquisitions to program remediation. Let’s take a look. The Securities…

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BCG Scores FCPA Declination

declination

The Justice Department has decided not to bring FCPA charges against Boston Consulting Group, crediting the firm for its prompt self-disclosure of bribery problems in Africa and for the painful financial consequences it imposed on the offending employees. Let’s dig into the declination letter and see what lessons the rest of the corporate compliance community…

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Archives, 2019: A Good FCPA Settlement

fcpa

Radical Compliance is taking an off-the-grid vacation for the next 10 days, so we are reprinting some of readers’ favorite posts from the archives. The following ran in February 2019. Now that we’ve had a long weekend to digest the FCPA enforcement action imposed against Cognizant Technologies last week, compliance officers have a lot more…

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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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