The Securities and Exchange Commission continues to rack up FCPA enforcement actions.  In its latest settlement, Clear Channel Outdoor Holdings agreed to pay $26.1 million for bribery violations committed by its former Chinese subsidiary.  According to Clear Channel, the Department of Justice closed its FCPA investigation.  Clear Channel, a San Antonio-based advertising company, paid bribes to Chinese government officials with cash, gift cards, first-class travel,...

Herbalife’s FCPA settlement is another one for books – the wreckage left includes two criminal indictments for Chinese officials who may never be apprehended, along with $123 million in penalties.  When going through the wreckage, there are serious issues of corporate failures at senior levels of the company along with pervasive and systemic misconduct in China.  What is surprising is the obvious red flags of...