Corruption, Crime & Compliance - Episode 208 - A Deep Dive into the WPP FCPA SEC Settlement
FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras
FCPA Compliance and Ethics Report-Episode 118-the Alstom FCPA Enforcement Action
FCPA Compliance and Ethics Report-Episode 88, Internal Controls for Third Parties Under the FCPA, Part I
The SEC continues to expand its cybersecurity enforcement authority to include allegations that a company's failure to monitor its managed security service providers (MSSP) amounts to violations of federal securities laws....more
The facts are frequently the same. A company that has retained the services of a vendor receives an authentic-looking email from the vendor’s CFO which advises that the vendor has changed its bank account or method of...more
The Nutter Securities Enforcement Update is a periodic summary of noteworthy recent securities enforcement activity, settlements, decisions, and charges. ...more
Authored by our Global Sanctions Team On 10 and 29 June 2022, Switzerland expanded existing sanctions and implemented new measures in response to Russia's ongoing military aggression in Ukraine. This new sanction set is in...more
When you look under the hood of FCPA enforcement actions, the schemes employed by corporate actors can be shocking. The “creativity” of bad actors can provide important lessons learned and help future investigators when...more
In this episode, Michael Volkov reviews the WPP SEC FCPA settlement. WPP, the Largest Global Advertising Group, Settles FCPA Charges with SEC for $19.2 Million. After a long hiatus, the SEC announced a settlement with WPP...more
The SEC’s FCPA enforcement action against WPP presents a number of important lessons learned, ranging from third-party risk management, properly responding to employee complaints and red flags, and failure to integrate...more
Deutsche Bank to Pay Over $130 Million to Resolve Foreign Corrupt Practices Act and Fraud Allegations - Deutsche Bank Aktiengesellschaft (Deutsche Bank) has agreed to pay more than $130 million to resolve the government’s...more
On October 15, 2020, the Securities and Exchange Commission issued a settled administrative order charging Andeavor LLC with failing to devise and maintain adequate internal controls surrounding its buyback of company stock...more
Department of Education Report Warns that Academic Institutions Are Failing to Meet Compliance Obligations in Fight Against Foreign Influence Last month the Department of Education (“DOE” or “Department”) released an...more
On October 15, 2020, the US Securities and Exchange Commission (SEC) issued a cease and desist order (Order), settling charges against a registrant for controls violations relating to a stock buyback plan implemented during...more
We previously discussed an SEC enforcement action against Andeavor LLC for controls violations relating to a stock buyback plan it implemented while it was in discussion to be acquired by Marathon Petroleum Corp. in 2018....more
In July 2020, a publicly traded pharmaceutical company entered into a settlement with the Securities and Exchange Commission, without admitting or denying findings, and agreed to pay a financial penalty relating to various...more
With the plunge in commodity prices many formerly profitable wells are now in the red, and we don’t know for how long. This is causing non-operators to question the bona fides of the operations … and of the operator, and to...more
OCC grants national banks the authority to provide cryptocurrency custody services for customers. On July 22, 2020, the Office of the Comptroller of the Currency (OCC) issued an interpretive letter (the letter) granting...more
On July 3, 2020, the U.S. Department of Justice and the Securities and Exchange Commission issued a Second Edition of the Resource Guide to the U.S. Foreign Corrupt Practices Act (the Guide), representing the Guide’s first...more
Compliance professionals, we need to talk about accounting controls again. They’re back in the news these days as an important part of FCPA compliance. In fairness, accounting controls have never stopped being an...more
On July 3, 2020, the U.S. Department of Justice (DOJ) and U.S. Securities and Exchange Commission (SEC) jointly released the second edition of the “Resource Guide to the U.S. Foreign Corrupt Practices Act,” which was...more
On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...more
• A payment to a government official can take many forms. • The SEC charges bank for books and records violation even absent a bribery charge. • Industry-wide enforcement is a continuing tactic for U.S. regulators. ...more
The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business. It also requires companies whose securities are listed in the US to make and keep...more
The United States Securities and Exchange Commission wrapped up its fiscal year on September 30, 2019 with a flurry of enforcement actions filed in the final weeks of the month. These cases will provide fodder for analysis...more
The big one finally is resolved. The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced yesterday. This massive case came in with multiple documents, a long list of...more
Asking a Brazilian-based company not to use the World Cup as a business development opportunity, most particularly when Brazil is hosting the World Cup, seems to be highly unlikely....more
After a long silence since guidance was last issued a year ago, there’s now widespread expectation that the Securities and Exchange Commission will get much more specific this year about new cybersecurity disclosures for...more