Tagged: SEC

Berger FCPA Settlement: Back to the Future

The recent Louis Berger International FCPA settlement highlighted once again the serious consequences from systemic bribery violations, the ease with which bribery schemes can be carried out, and the risks facing all global companies, especially those involved in high-risk industries like construction projects. Berger agreed to pay $17 million to settle the case and agreed to a three-year corporate monitor. Interestingly, at the same time...

Private Equity’s Corruption Risk Underbelly — Portfolio Companies

FCPA enforcement will likely take a turn into the private equity industry. I know this is a regular claim by FCPA practitioners but we already can see the beginning of the trend. The “princeling” investigations are ongoing and the industry is fighting back, claiming that internships awarded to family members of foreign officials were not given with corrupt intent or were not of any value...

Webinar: Managing Private Equity Corruption Risks

Date: Tuesday, August 11, 2015 Time: 12 Noon EST Sign Up Here Justice Department and SEC prosecutors are devoting greater attention to private equity FCPA enforcement. This coincides with increased SEC regulation and examination of the private equity industry. Private equity companies face significant corruption risks in global markets. From sovereign wealth funds to portfolio companies, private equity compliance officers have to design and implement...

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 lconnell@volkovlaw.com. 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)....

Washington Politics and Compliance

Consider this posting a warning to everyone in the corporate governance field. I am not known for being a chicken little and screaming “the sky is falling, the sky is falling.” I tend to be a realist when it comes to politics and corporate governance. So with this caveat in mind, here is my warning for the future. With the rise of the Chief Compliance...

Gifts, Meals and Prosecution: BHP Billiton’s Settlement

The SEC is on a mission – companies that engage in egregious payment schemes for gifts, hospitality and travel are going to get prosecuted for civil FCPA violations. Recent SEC enforcement actions against companies continue, and BHP Billiton’s settlement last week is another example of the SEC’s prosecution strategy. BHP Billiton agreed to pay a $25 million penalty to settle SEC charges for internal controls...