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‘Enforcement 40’ for 2020
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Join the Securities Litigation and Enforcement Group on LinkedInActing Principal Deputy Assistant Attorney General Nicole Argentieri On …. – FCPA Professor
Yesterday Acting Principal Deputy Assistant Attorney General Nicole Argentieri delivered this speech at the annual FCPA dog and pony show. Argentieri addressed four topics: (1) the DOJ “achievements this year in the fight against corruption and white collar crime; (2) how the DOJ is “actioning the recent corporate enforcement policies announced by the department — policies […]
Does The SEC Even Need A Specific FCPA Unit? – FCPA Professor
The small percentage of FCPA enforcement actions as a total of overall SEC enforcement actions in FY2023 was not an aberration. In FY2022, FCPA enforcement actions comprised just 1% of the SEC’s overall enforcement actions; in FY2021, FCPA enforcement actions comprised just 1% of the SEC’s overall enforcement actions; in FY2020 FCPA enforcement actions comprised […]
SEC Charges Clear Channel Outdoor with FCPA Violations Relating to China Subsidiary
The Securities and Exchange Commission today announced that Clear Channel Outdoor Holdings Inc. agreed to pay more than $26 million to resolve charges that it bribed Chinese government officials to obtain outdoor advertising contracts in violation of the Foreign Corrupt Practices Act (FCPA). The SEC’s order finds that Clear Channel, a U.S. based company in […]
SEC Charges 3M with Foreign Corrupt Practices Act Violations Relating to China Subsidiary
The Securities and Exchange Commission today announced that 3M Company agreed to pay more than $6.5 million to resolve charges that it violated the books and records and internal controls provisions of the Foreign Corrupt Practices Act (FCPA). The SEC’s order finds that employees of a 3M wholly owned subsidiary based in China arranged for […]
Colombian Conglomerate Grupo Aval and Its Bank Subsidiary to Pay $40 Million to Settle FCPA Violations
The Securities and Exchange Commission today charged Colombian conglomerate Grupo Aval Acciones y Valores S.A., aka Grupo Aval S.A., and its bank subsidiary, Corporación Financiera Colombiana S.A. (Corficolombiana), with violating the Foreign Corrupt Practices Act (FCPA). Grupo Aval, whose shares are traded on the New York Stock Exchange, agreed to pay $40 million to settle […]
The most bizarre FCPA disclosure I’ve ever seen | The FCPA Blog
Through the normal course of research, I review a lot of SEC filings. Over the years, I’ve probably thumbed through more than ten thousand. This has to be the most bizarre SEC filing disclosure related to the FCPA I’ve come across. The filer — Beyond Air, Inc. — is a biomedical company that uses a […]
Thus Far From The SEC – FCPA Professor
Thus far in 2023, the SEC has brought four FCPA enforcement actions. All of the enforcement actions have been against foreign issuers. All of the enforcement actions have been resolved through an administrative order (meaning there was no judicial scrutiny whatsoever). All of the enforcement actions have lacked related enforcement actions against individuals. Source: Thus […]
Dutch Medical Supplier Philips to Pay More Than $62 Million to Settle FCPA Charges
The Securities and Exchange Commission today announced that Amsterdam-based Koninklijke Philips N.V. will pay more than $62 million to resolve charges that it violated the Foreign Corrupt Practices Act (FCPA) with respect to conduct related to its sales of medical diagnostic equipment in China. According to the SEC’s order, Philips’ subsidiaries in China, cumulatively referred […]
Stryker discloses new FCPA investigation after two prior enforcement actions | The FCPA Blog
Medical device-make Stryker Corporation — which resolved FCPA cases in 2013 and 2018 — said Tuesday in an SEC filing that it is “currently investigating whether certain business activities in a foreign country violated provisions of the Foreign Corrupt Practices Act.” Stryker, based in Kalamazoo, Michigan, said it has “engaged outside counsel to conduct” the […]
The Gap In SEC Individual FCPA Enforcement Actions Is Now 2.5 Years – FCPA Professor
The last individual FCPA enforcement action by the SEC occurred in October 2020 (a gap that is now approximately 2.5 years). This 2.5 gap is the most significant gap in individual FCPA enforcement by the SEC in nearly a decade and is approaching the longest gap in approximately 20 years. (See here). Since October 2020 there have […]