Search results for: fcpa
Lessons From Deere FCPA Sanction
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…
Read MoreBCG Scores FCPA 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…
Read MoreArchives, 2019: A Good FCPA Settlement
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…
Read MoreAnother FCPA Action With No Monitor
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…
Read MoreSwiss Trader Gunvor Pays $661M on FCPA Fails
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…
Read MoreSAP Pays $220M on FCPA Violations
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…
Read MoreLessons in Freepoint FCPA Settlement
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…
Read MoreSome Vague Hints on Analytics, 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,…
Read MoreTwo New FCPA Settlements
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.,…
Read MoreThat Clear Channel FCPA Settlement
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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