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.
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
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.
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.BareTraps Auburn Women B07B9LSMHB s Jaylyn Jaylyn Slide Sandal Auburn bfc5c01
Glencore plc, an Anglo–Swiss mining company with headquarters in Switzerland and ADRs traded on a U.S. exchange recently announced:
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.