Archiv der Kategorie: Compliance
Mergers and Acquisitions Under the FCPA, Part I
Today, I begin a three-part series on mergers and acquisitions under the Foreign Corrupt Practices Act. Today I will review the pre-acquisition phase, focusing the information and issues you should review, tomorrow in Part II, I will look at how … Weiterlesen
Mid-Year FCPA Report, Part II
Today, I continue my look at what I think were some of the most significant highlights from the first half of 2014 relating to the Foreign Corrupt Practices Act (FCPA). Yesterday, the focus was on corporate and individual enforcement. Today … Weiterlesen
Common Sense in the Definition of ‘Instrumentality’ Under the FCPA
In what can only be called a judicial decision based on common sense the 11th Circuit Court of Appeals, in an opinion released on May 16, upheld the convictions of Joel Esquenazi and Carlos Rodriguez for violations of the Foreign … Weiterlesen
SEC Sanctions Company for Whistleblower Retaliation
I drove my daughter to the airport today for her summer exchange program in Spain. On the way she asked me what I was going to blog about tomorrow and I told her whistleblowers. She was not familiar with that … Weiterlesen
The Magna Carta and Scrutiny of Your Compliance Program
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The HP FCPA Settlement
Last week the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) jointly announced the conclusion of a Foreign Corrupt Practices Act (FCPA) enforcement action against Hewlett-Packard Company (HP). In the settlement, HP agreed to pay $108MM in fines, … Weiterlesen
Joint Venture Partners and the Company You Keep Under the FCPA
As the father of a teenage daughter I am sometimes, reluctantly, forced to admit that upon rare occasions my parents were right about a few things. One was asking for permission first rather than asking for forgiveness after the fact, … Weiterlesen
When to Bring in Investigative Counsel and Why
When should you bring in a true outsider to handle an internal investigation? What about specialized investigative counsel? Jim McGrath, who often writes about the need for specialized investigative counsel, has also pointed out on several occasions that having an … Weiterlesen
Getting Your Company Ready for M&A Compliance Due Diligence
Who was the absolute worst general during the Civil War? While there are many worthy candidates for this dubious honor, on the Southern side my vote goes to General John Bell Hood. One of the prime proponents of the Southern … Weiterlesen
Five Golden Rules of What Works – The Internal Marketing of Compliance
I am attending the ACI Foreign Corrupt Practices Act (FCPA) Boot Camp in Houston. It is one of the best FCPA events held in Houston annually. It brings together some of the top local compliance talent, together with top national … Weiterlesen
