The Impact Of Kiobel On FCPA Enforcement
Yesterday, the Supreme Court released its long-awaited opinion in Kiobel v. Royal Dutch Shell Petroleum. The precise issue before the court was “whether and under what circumstances courts may...
View ArticleForeign Military Sales Lead To FCPA Enforcement Action
[This post is part of a periodic series regarding "old" FCPA enforcement actions] In 1989, the DOJ criminally charged Minnesota based military equipment and supplies company Venturian Corporation,...
View ArticleIn Depth On The Weatherford Enforcement Action
Last week, the DOJ and SEC announced (here and here) that Switzerland-based oil and gas services company Weatherford International agreed to resolve a Foreign Corrupt Practices Act enforcement action...
View ArticleGerman Company Resolves FCPA Enforcement Action Based On Conduct From “The...
Approximately 8 years ago, a German company owned 80% of a German entity doing business in Nigeria. The German entity doing business in Nigeria entered into a joint venture consortium agreement with...
View ArticleIn Depth On The ADM Enforcement Action
On December 20th, the DOJ and SEC announced (here and here) that Archer Daniels Midland Company (“ADM”) agreed to resolve a Foreign Corrupt Practices Act based on the conduct of an indirect subsidiary...
View ArticleMarubeni Enforcement Action Specifics
A post last week mentioned the $88 million Foreign Corrupt Practices Act enforcement action (the 12th largest of all-time in terms of settlement amount) against Marubeni (a Japanese company). In 2012,...
View ArticleHP Enforcement Action – Where To Begin?
Where to begin? That is the question when analyzing last week’s $108 million Foreign Corrupt Practices Act enforcement action against HP and related entities. (See here). Should the title of this post...
View ArticleIs The DOJ Picking on Non-U.S. Companies and Individuals?
Today’s post is from David Simon (Foley & Lardner). ***** The debate over whether the United States should impose its values on the rest of the world through enforcement of the Foreign Corrupt...
View ArticleNon-FCPA Legal Developments Should Cause Pause As To Certain FCPA Enforcement...
The substance of this post is the same as this August 2013 post regarding the civil RICO action involving Pemex and Siemens. The only difference is that instead of a S.D. of New York decision that...
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The DOJ Gets Benchslapped In Foreign Bribery Case
In recent FCPA year in reviews (see here for 2014 and here for 2013) topics have included judicial scrutiny of non-FCPA cases because the decisions (mostly concerning jurisdictional issues relevant to...
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Issues To Consider From The PTC Enforcement Action
This post went in-depth regarding this week’s $28 million Foreign Corrupt Practices Act enforcement action against PTC Inc. and related entities. This post continues the analysis by highlighting...
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Issues To Consider From The VimpelCom Enforcement Action
This prior post went in-depth into the recent Foreign Corrupt Practices Act enforcement action against VimpelCom (and a related entity) that resulted in a net $397.5 million FCPA settlement – the 5th...
View ArticleGerman Company Resolves FCPA Enforcement Action Based On Conduct From “The...
Approximately 8 years ago, a German company owned 80% of a German entity doing business in Nigeria. The German entity doing business in Nigeria entered into a joint venture consortium agreement with...
View ArticleIn Depth On The ADM Enforcement Action
On December 20th, the DOJ and SEC announced (here and here) that Archer Daniels Midland Company (“ADM”) agreed to resolve a Foreign Corrupt Practices Act based on the conduct of an indirect subsidiary...
View ArticleMarubeni Enforcement Action Specifics
A post last week mentioned the $88 million Foreign Corrupt Practices Act enforcement action (the 12th largest of all-time in terms of settlement amount) against Marubeni (a Japanese company). In 2012,...
View ArticleHP Enforcement Action – Where To Begin?
Where to begin? That is the question when analyzing last week’s $108 million Foreign Corrupt Practices Act enforcement action against HP and related entities. (See here). Should the title of this post...
View ArticleIs The DOJ Picking on Non-U.S. Companies and Individuals?
Today’s post is from David Simon (Foley & Lardner). ***** The debate over whether the United States should impose its values on the rest of the world through enforcement of the Foreign Corrupt...
View ArticleNon-FCPA Legal Developments Should Cause Pause As To Certain FCPA Enforcement...
The substance of this post is the same as this August 2013 post regarding the civil RICO action involving Pemex and Siemens. The only difference is that instead of a S.D. of New York decision that...
View ArticleClik here to view.
The DOJ Gets Benchslapped In Foreign Bribery Case
In recent FCPA year in reviews (see here for 2014 and here for 2013) topics have included judicial scrutiny of non-FCPA cases because the decisions (mostly concerning jurisdictional issues relevant to...
View ArticleClik here to view.
Issues To Consider From The PTC Enforcement Action
This post went in-depth regarding this week’s $28 million Foreign Corrupt Practices Act enforcement action against PTC Inc. and related entities. This post continues the analysis by highlighting...
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