Schlagwort-Archive: Department of Justice
SEC Charges Total S.A. for Illegal Payments to Iranian Official
Washington, D.C., May 29, 2013 — The Securities and Exchange Commission today charged France-based oil and gas company Total S.A. with violating the Foreign Corrupt Practices Act (FCPA) by paying $60 million in bribes to intermediaries of an Iranian government … Weiterlesen
Don’t Claim it is Legal to Bribe Another Government’s Representatives – Especially in China
Last week a guest blog post in the FCPA Blog by Ernesto Sanchez, entitled “What’s good for reciprocity may be bad for FCPA prosecutions”, implied that the US District Court’s ruling when it “vacated an SEC Dodd-Frank rule mandating that … Weiterlesen
FCPA: What is Your Compliance Strategy?
Do you have a strategy? The Houston Astros claim to have a strategy that involves being the worst team in baseball for up to the next five years and then magically they will become a winner. I suppose that having … Weiterlesen
FCPA: DPAs and NPAs – Useful Tools to Achieve Compliance
The debate on whether the use of Deferred Prosecution Agreements (DPAs) and Non-Prosecution Agreements (NPAs) has become lively again over the past couple of weeks. Last week, there was a panel hosted by the Corporate Crime Reporter conference at the … Weiterlesen
FCPA: From the Compact Model to the Luxury Model – Managing Your Third Party Risk
I am currently attending the Hanson Wade Oil and Gas Supply Chain Compliance conference in Houston. The event is excellent and the presentations have been ‘spot on’ for the nuts and bolts of how to do compliance. As the conference … Weiterlesen
ILR: DOJ Got a Record $9B in Corporate Settlements in 2012
Corporate Counsel: Federal enforcers obtained a whopping $9 billion in corporate settlements in 2012—a record amount that surpassed the previous high set in 2006 by nearly $3 billion. Read more: DOJ Got a Record $9B in Corporate Settlements in 2012
FCPA: How to Introduce Change into Your FCPA Compliance Program (Without Blowing It Up)
Thucydides or Herodotus; Herodotus or Thucydides. Which is your favorite? I admit to vacillating between the two. Thucydides wrote about the end of the Athenian dynasty from the Peloponnesian War and the debacle of the Sicilian Invasion. Herodotus wrote about … Weiterlesen
FCPA: Doing Business In Italy-Step Up Your FCPA Compliance Now
Ed. Note-I met last week with Craig Bloom, a colleague who practices law in Houston. Craig, who is fluent in Italian, was telling me about some of the compliance issues that have been percolating in Italy and in Italian companies. … Weiterlesen
FCPA: Distributors under the FCPA
If there was ever a question that distributors were covered under the Foreign Corrupt Practices Act (FCPA), in 2012, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) made it emphatically clear that this class of entities in … Weiterlesen
Amnesty for Armstrong? Lessons for the Compliance Practitioner
The Lance Armstrong saga continues to provide many lessons for the compliance practitioner. A recent article on ESPN.com, entitled “Lance calls for amnesty program”, reported that Armstrong has come out in favor of those who openly speak about the doping … Weiterlesen
