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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The Monaco Speech, Part II

fcpa

Today let’s return to that speech that deputy attorney general Lisa Monaco delivered last week at the Society of Corporate Compliance & Ethics annual conference. Monaco’s announcement of a new safe harbor policy for acquisitions got the headlines, but there was plenty else in her remarks that also deserves our attention. For starters, Monaco talked…

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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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Important Case on Investigations

investigations

An important update from the world of internal investigations: a federal judge has ruled against two former executives of Cognizant Technologies, who had been arguing that Cognizant had acted as a de facto arm of the government when the company investigated the two about their role in a corruption scheme.  The ruling came down from…

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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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More on ‘Extraordinary’ Cooperation

fcpa

Still wondering what the Justice Department means when it says it wants “immediate” self-disclosure of corporate misconduct and “extraordinary” cooperation and remediation for severe FCPA cases? Good news: we now have a bit more understanding of those terms, straight from the Justice Department official who coined them. Assistant attorney general Kenneth Polite, who has been…

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The Latest FCPA Declination

corsa

We have yet another example of the Justice Department trying to put its new corporate misconduct policies into practice, allowing a Pennsylvania coal company to pay only $1.2 million to settle FCPA charges thanks to the company’s voluntary self-disclosure and other cooperative actions. The company in question is Corsa Coal Corp., a company that does…

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