On September 21, 2016, Mary Jo White, Chair of the U.S. Securities and Exchange Commission (SEC) spoke at a Legal Practice Division Luncheon at the International Bar Association Annual Conference. She discussed the...more
After a relatively slow year of Foreign Corrupt Practices Act (FCPA) prosecutions in 2015, this year started out with a landmark settlement against telecommunications provider VimpelCom Ltd. DC Partner Mark Srere, Denver...more
7/22/2016
/ Alcoa ,
Alstom ,
Benchmarking ,
Chief Compliance Officers ,
Compliance ,
Corporate Counsel ,
Enforcement Actions ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
KBR (formerly Kellogg Brown & Root) ,
Siemens ,
VimpelCom
For the next year, the Justice Department may be offering up to a 50% discount on fines imposed in FCPA cases. Yesterday, the U.S. Department of Justice’s (“DOJ”) Criminal Division announced the launch of a one-year pilot...more
4/7/2016
/ Compliance ,
Cooperation ,
Corporate Counsel ,
Corporate Misconduct ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Individual Accountability ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes
On March 1, 2016, the SEC announced that Qualcomm Incorporated, a San Diego-based wireless telecommunication product company, agreed to pay $7.5 million to settle charges that its actions violated the Foreign Corrupt...more
3/31/2016
/ Books & Records ,
China ,
Compliance ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Internal Controls ,
Meals-Gifts-and Entertainment Rules ,
Neither Admit Nor Deny Settlements ,
Popular ,
Qualcomm ,
Securities and Exchange Commission (SEC)
On Tuesday, March 8, 2016, in conjunction with announcing a recent $2 million whistleblower award, Sean McKessey, Chief of the Office of the Whistleblower, stated that the SEC continues to see “a significant uptick” in the...more
The Securities and Exchange Commission’s (SEC) recent Foreign Corrupt Practices Act (FCPA) settlements focus on companies’ lack of sufficient anti-corruption compliance programs, which means, to the SEC, that the companies...more
2/17/2016
/ Anti-Corruption ,
BHP Billiton ,
Books & Records ,
Bribery ,
Compliance ,
Corporate Counsel ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Internal Controls ,
SAP SE ,
Securities and Exchange Commission (SEC) ,
Young Lawyers