Tagged: gifts and hospitality

Telefônica Brasil Pays $4.125 Million for Hospitality-Related FCPA Violations

Telefônica Brasil Pays $4.125 Million for Hospitality-Related FCPA Violations

As the old adage provides – better late than never.  (Same applies for my somewhat tardy posting on this case). Telefônica Brasil settled FCPA violations with the SEC for a pretty penny — $4.125 million in civil penalties in connection its hospitality program for the 2014 World Cup and 2013 Confederations Cup According to the settlement agreement, Telefônica Brasil failed to maintain adequate internal controls...

SciClone Pharmaceuticals: A Textbook Case of FCPA Violations for Gifts, Meals, Entertainment and Travel

The Securities and Exchange Commission continues its steady march as the prominent FCPA enforcement agency against corporations.  The Justice Department has not brought any enforcement actions this year and continues to reevaluate its FCPA compliance program. In an interesting enforcement action, the SEC settled a case with SciClone Pharmaceuticals for $12.8 million for violations occurring in China. Unlike many other SEC enforcement actions, the SEC’s...

Encouraging Employees to Break the “Rules” to Do the Right Thing

Lauren Connell of The Volkov Law Group joins us again for a posting about corruption and gifts and hospitality.  Her profile is here and she can be reached at [email protected]. Laws and regulations draw black lines in often-gray areas. That is their purpose; they exist to make it easier to tell what is “wrong” and what is “right” (as defined by whoever made the law)....