The Federal Trade Commission is cracking down on companies that falsely certify compliance with the United States and EU safe harbor framework on data protection. Expect that scrutiny to only intensify in the coming year. Developed in 2000 by the U.S. Department of Commerce and the European Commission, the U.S.-EU Safe Harbor Framework establishes a […]
Anti-Bribery
Corruption Comes Home to Roost
LONDON—And suddenly, within the space of a week, ethics & compliance officers have all the ammunition they need to tell cynics once and for all why eradicating corruption is so important. Here in the United Kingdom (where I am spending the week on business), the word “war” is on the front page of every newspaper […]
U.K. Bribery Charges in the Offing for France’s Alstom
Bloomberg News reported last week that French train manufacturer Alstom SA will be charged with violating U.K. bribery laws following a five-year investigation, citing two sources with knowledge of the investigation. The sources, who requested anonymity, told the news outlet that the U.K.’s Serious Fraud Office may seek charges to be approved by the attorney […]
Walmart: FCPA Probe Could Reach $240 Million
Walmart disclosed in a quarterly earnings report yesterday that it could end up shelling out as much as $240 million in the next fiscal year for compliance enhancements and investigation costs related to possible violations of the Foreign Corrupt Practices Act. “We anticipate expenses for FCPA matters and compliance-related enhancements to range between $200 and […]
Pfizer’s Head of Government Investigations Joins Paul Hastings
Gary Giampetruzzi, former assistant general counsel and head of government investigations at Pfizer, has joined the law firm Paul Hastings as a partner in the New York office. During his 13 years with Pfizer, Giampetruzzi held various posts, including as a deputy compliance officer, where he led the build out of the company’s anti-corruption and […]
Mead Johnson Warns of Possible FCPA Violations
Mead Johnson Nutrition announced this week in a Form 10-K filing with the Securities and Exchange Commission that it has launched an internal investigation into potential violations of the Foreign Corrupt Practices Act. In October 2013, the SEC launched an investigation into whether a Chinese subsidiary of the infant formula maker inflated formula prices in […]
Shop Talk: Fostering a Culture of Compliance and Ethics
Let’s be honest: Stating what the company’s values are is easy. Integrity, quality, passion, accountability, collaboration—they’re in mission statements from one coast of Corporate America to the other. CEOs and board directors rattle them off all the time, to anyone who’ll listen, with all the confidence of an ad executive pitching a hot new client. […]
SFO Issues Guidance for Deferred Prosecution Agreements
The director of the Serious Fraud Office and the director of Public Prosecutions published a joint code of practice on the use of deferred prosecution agreements, a new enforcement tool that will become available to prosecutors on Feb. 24. The U.K. announced plans to introduce DPAs in October 2012. They later were introduced in the […]


