All FCPA articles – Page 14
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Blog
Credit Suisse subsidiary settles FCPA violations
The SEC has announced that Credit Suisse Group AG will pay $30 million to settle allegations that it rigged hiring practices to win business in the obtained investment banking business in the Asia-Pacific region, an FCPA violation. Credit Suisse also agreed to a $47 million settlement with the Justice Department.
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Hiring and the FCPA
The Credit Suisse FCPA enforcement action reminds us all again that it is not the hiring of family members or close friends of a foreign government official or employee of a state-owned enterprise that is illegal under the FCPA, only those hires made with corrupt intent.
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What is the cost of a subpoena?
Glencore has seen a drop in its share price, which could be related to the Justice Department having issued a subpoena for possible FCPA violations in the Democratic Republic of Congo, Nigeria, and Venezuela.
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Irony, FCPA enforcement actions, and M&A
Boeing’s planned acquisition of Brazilian company Embraer’s commercial jet business and LyondellBassell’s possible acquisition of Brazilian entity Braskem highlights an ironic twist to the FCPA: An enforcement action could be so financially draining that your company is forced to sell all or parts of itself, but results from that same ...
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Blog
Beam Suntory to pay $8M in FCPA case
Beam Suntory subsidiary Beam India was charged by the SEC with making improper payments to various government officials to obtain or retain business in the Indian market. Beam was fined $8M, but neither admitted nor denied the the allegations.
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Shell companies and the who of corruption
A key part of any fraud scheme are the attempts to keep it hidden, and many companies set up shell companies to do just that. A look at why shell companies can shield bad actors from the public record.
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Whistleblowers and building trust
It is now more important than ever for companies to take seriously internal whistleblower reports, get the reports into the hands of the corporate functions that can triage and investigate such information, and keep the whistleblower in the loop more fully as to the status of the investigation.
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The importance of compliance contract terms
Making sure third-party contracts contain appropriate compliance terms and conditions can help save companies time and money down the road.
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Asking questions about your third-party process
When regulators come knocking, it’s important to have the right protocols in place. Knowing what questions to ask can be a big help to companies when implementing a third-party due diligence process.
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No piling on requires global disclosure and cooperation
To receive the benefits of no piling on, companies must fully disclose their conduct and cooperate with regulators across the globe.
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Condos, corruption, and compliance
While President Trump promised condos in North Korea as a part of his negotiations with North Korean Supreme Leader Kim Jung Un, it doesn’t mean companies will have an easy time doing business in the country, which ranked as “highly corrupt,” on the 2017 Transparency International Corruption Perceptions Index.
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What is due diligence?
Due diligence is key to getting your third-party risk management program off the ground.
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Business justification for the use of third parties
Why is business justification for third parties so important? With the Department of Justice, Securities and Exchange Commission, and Internal Revenue Service all seeking such justification, companies should definitely make it part of the compliance process.
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Best practices: Hiring a business sponsor for third-party relationships
A significant piece of the compliance regime is overseeing third-party business relationships, and the best way to keep them on track is to employ the business sponsor.
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Executives behaving badly—at what cost?
FCPA violations from SocGen and Legg Mason may point to a new trend of holding the C-Suite accountable, but will voluntary resignations be seen as enough of a penalty?
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Blog
Credit Suisse to pay $47M in FCPA fines over hiring practices
Credit Suisse has become the latest financial institution to pay a penalty—to the tune of $47 million—and enter a non-prosecution agreement with the Department of Justice concerning questionable hiring practices in the Asia Pacific region.
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Legg Mason to pay $64.2M in FCPA case
Investment management firm Legg Mason entered a non-prosecution agreement and agreed to pay $64.2 million to resolve an investigation into violations of the Foreign Corrupt Practices Act concerning Legg Mason’s participation in a Libyan bribery scheme, the Department of Justice announced.
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Blog
SocGen to pay $860M in FCPA and LIBOR case
French banking group Société Générale and its wholly owned subsidiary, SGA Société Générale Acceptance, will pay a combined total penalty of more than $860 million to resolve charges with criminal authorities in the United States and France, the Department of Justice announced June 4.
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Blog
Legg Mason accrues $67M charge to earnings for FCPA matter
U.S. investment management firm Legg Mason disclosed in a securities filing on May 30 that it expects to soon complete negotiations with both the U.S. Department of Justice and the SEC to resolve a Foreign Corrupt Practices Act investigation.
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ArticleDeputy Attorney General Rod Rosenstein keynote: The value of compliance
Deputy Attorney General Rod Rosenstein kicked off Compliance Week 2018 in Washington D.C. on Monday, speaking candidly about compliance program effectiveness, the FCPA Corporate Enforcement Policy, the newly announced Justice Department coordination policy, and much more.