When you look under the hood of FCPA enforcement actions, the schemes employed by corporate actors can be shocking. The “creativity” of bad actors can provide important lessons learned and help future investigators when trying to unearth bribery schemes. At the root of most schemes is brazen arrogance and rationalization of otherwise improper behavior. South Korea From 2009 to 2017, KT high-level executives maintained slush...
Bausch Health agreed to pay the SEC $45 million to settle Valeant Pharmaceuticals (former name) accounting fraud schemes. Three former executives, former CEO Michael Pearson, CFO Howard Schiller and Controller Tanya Carro also settled with SEC. Pearson agreed to pay a civil penalty of $250,000 and repaid Bausch $450,000 in compensation; Schiller agreed to pay a civil penalty of $100,000 and repaid Bausch $110,000 in...
The Cognizant bribery scheme is another in the line of illegal conspiracies orchestrated by senior management – but this one is even more disturbing for a number of reasons. Cognizant’s former president and general counsel directed the scheme in full consultation and with full knowledge and intent with the chief operating officer and the vice president of administration. Add Cognizant to the list of companies...
On December 19, 2018, the SEC announced settlements with two former senior executives of Panasonic Avionics Corporation. In April 2018, Panasonic Avionics settled FCPA charges with the Justice Department and the SEC and agreed to pay $280 million. (Here) Paul Margis (Here), the former CEO, and Takeshi Uonaga (Here), the former CFO, agreed to pay $75,000, and $50,000 respectively, to settle books and records and...
