The SEC’s FCPA enforcement action against WPP presents a number of important lessons learned, ranging from third-party risk management, properly responding to employee complaints and red flags, and failure to integrate acquisition targets into existing compliance programs.  At bottom, WPP and its subsidiaries lacked any culture of compliance.  While it is easy to cite all the deficiencies in the WPP subsidiaries, such a focus misses...

The Novartis and Alcon FCPA enforcement action is chock full of interesting issues.  See Novartis DPA Here , Alcon DPA Here and SEC Novartis Order Here. At the outset, Novartis is “lucky” – the settlement is relatively positive, despite its 2016 SEC enforcement action in China.  Given Novartis weak culture of compliance (if anything, a better description may be a culture of non-compliance) and its...

In a record setting FCPA enforcement day, the SEC settled three separate FCPA enforcement actions on Friday, September 27, 2019.  The three cases involved: Quad/Graphics, a Wisconsin company; Barclays Bank, a global bank, and Westport Energy, a clean energy company, and its former CEO, Nancy Gougarty.  Each of the cases involved interesting enforcement facts and situations. in this Episode, Michael Volkov reviews each case and...

In June 2018, the SEC announced an FCPA settlement with Beam Suntory for violations in India.  Beam’s settlement totaled over $8 million.  Beam’s conduct involved illegal payments made through third-party representatives to increase Beam’s sales, product placement and secure appropriate registrations and approvals needed to distribute liquor in India.  Beam also did not receive any remediation credit for its failure to adequately respond to and...