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What Do These Companies And Firms Have In Common?

July 9, 2018

Wal-Mart, Amazon, GE Healthcare, Oracle, Lowes, SAP, Las Vegas Sands, Olympus, Post Holdings, McDermott International, Caesars Entertainment, Micron Technology, ADM, Cummins, Discover Financial Services, KBR, Halliburton, Johnson & Johnson, Crawford Co., Realogy Holdings, CVS Caremark, Ensco, HCA Healthcare, Carnival Cruise Line, Olin Corp., CB&I, Abbott, Wells Fargo, 3M, Briggs & Stratton, Sherwin Williams, Standard Motor Products, Graebel, Allison Transmission, and many  more.

Debevoise & Plimpton, King & Spalding, Hogan Lovells, Greenberg Traurig, Bryan Cave, Squire Patton Boggs, Foley & Larder, Hughes Hubbard & Reed, Bass Berry & Sims, Perkins Coie, Pepper Hamilton, Seyfath Shaw, Quarles & Brady, Troutman Sanders, Stinson Leonard, Littler Mendelson, Barnes & Thornburg, and many more.

The answer is below the fold.

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A Preview Of Seng’s Appeal

July 9, 2018

Foreign Corrupt Practices Act appeals are not as rare as Halley’s Comet, but nevertheless rare. Thus, when an FCPA appeal occurs and an appellate court is presented with the opportunity to construe the law, almost be definition, it is a big deal.

As highlighted in this prior post, in July 2017 after a long trial a federal jury convicted Ng Lap Seng of two counts of violating the FCPA, one count of paying bribes and gratuities, one count of money laundering and two counts of conspiracy “for his role in a scheme to bribe United Nations ambassadors to obtain support to build a conference center in Macau that would host, among other events, the annual United Nations Global South-South Development Expo.” Thereafter, Seng was sentenced to 48 months in prison and three years of supervised release. In addition, Seng was ordered to pay a $1 million fine, $302, 977 in restitution to the United Nations and the judge also ordered a forfeiture money judgment of $1.5 million. Continue Reading

This Week On FCPA Professor

July 7, 2018

FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.”

Set forth below are the topics discussed this week on FCPA Professor.

This post highlights what you need to know from the second quarter regarding FCPA enforcement and related developments and this post represents a mid-year FCPA report.

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Friday Roundup

July 6, 2018

Scrutiny alert, some responsibility, repeat offender, proposed changes to whistleblower rules, and for the reading stack. It’s all here in the Friday roundup.

NIKE Mens Mens Kawa Shower Photo 19998 NIKE Blue/White 754f5a7

Scrutiny Alert

Glencore plc, an Anglo–Swiss mining company with headquarters in Switzerland and ADRs traded on a U.S. exchange recently announced:

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Next Up – A $77 Million Enforcement Action Against Credit Suisse

July 5, 2018

First, it was BNY Mellon Corp. in August 2015 for $14.8 million (see here and here for prior posts). Then, it was Qualcomm in March 2016 for $7.5 million (see here and here for prior posts). Then, it was JPMorgan in November 2016 for $202.6 million (see here, here, and here for prior posts).

Next up in Foreign Corrupt Practices Act enforcement actions (mostly targeting the financial services industry) focusing, in whole or in part, on internship and hiring practices being a form of bribery is Credit Suisse as the DOJ and SEC officially announced today (see here and here) the expected enforcement action (see here).

If you were wondering whether this “scurrilous and hypocritical” form of FCPA enforcement action (as stated by a former SEC Chairman see here) would carry forward to the Trump administration, you now have the answer.

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