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…

Read More

FEPA: A Huge Step on Foreign Bribery

corruption

We have a Christmas season surprise for all you anti-corruption enthusiasts out there! Washington has just passed the Foreign Extortion Prevention Act, a law that makes it a crime for foreign government officials to demand or accept a bribe from a U.S. company. FEPA, as the legislation will now be forever abbreviated, was folded into…

Read More

Some Vague Hints on Analytics, FCPA

compliance program

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 More

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.,…

Read More

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…

Read More

The Monaco Speech, Part II

compliance program

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…

Read More

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…

Read More

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…

Read More

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…

Read More

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…

Read More