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Earth To Secretary Ross … There Have Been Numerous FCPA Enforcement Actions Concerning Conduct In India

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This is the second installment in the “earth to Secretary Ross” series. (See here for the first).

Recently, U.S. Commerce Secretary Wilbur Ross delivered this speech in India at a trade conference and remarked: “we are excited that so many U.S. companies are dedicated to building commercial relationships with the countries and customers in this region of the world.”

During the speech, Ross stated: “our strict Foreign Corrupt Practices Act also assures the Indian government that our companies will not cause scandals here.”

Earth to Secretary Ross … there have been numerous corporate FCPA enforcement actions concerning conduct, in whole or in part, in India as highlighted below.

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Issues To Consider From The Telefonica Brasil Enforcement Action

Issues

This previous post went in-depth into the recent $4.1 million FCPA enforcement action against Telefonica Brasil and this post continues the analysis by highlighting additional issues to consider.

What Is The U.S. Interest?

According to the SEC, Telefonica Brasil (a subsidiary of Spanish multinational Telefonica S.A. and the largest telecom company in Brazil with 34,000 employees and $14 billion in revenue) purchased 1,860 World Cup tickets for a total of approximately $5.1 million “for relationship-building activities with strategic audiences.”

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FCPA Institute – Minneapolis (June 20-21st) – Think Of It As “FCPA Summer School” With CLE Credit

summerschool

Summer is not just a time for children to elevate their knowledge and skills, but adults as well.

Professionals in the FCPA space – or wishing to join the FCPA space – can elevate their Foreign Corrupt Practices Act knowledge and practical skills at the FCPA Institute – Minneapolis on June 20-21st.

Think of it as “FCPA Summer School” with CLE credit and other professional credentials.

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This Week On FCPA Professor

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FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.”

Set forth below are the topics discussed this week on FCPA Professor.

This post highlights how a Brazilian telecom company (Telefonica Brasil) hosted Brazilian government officials for soccer tournaments in Brazil and then five years later the U.S. government collects $4.1 million in an FCPA enforcement action.

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A Brazilian Telecom Company Hosted Brazilian Government Officials For Soccer Tournaments In Brazil – Five Years Later, U.S. Collects $4.1 Million In FCPA Enforcement Action

Uncle Sam3

It is only fitting that one day after publishing this post regarding the SEC’s inconsistent enforcement of the Foreign Corrupt Practices Act (and how the SEC resolved an FCPA books and records and internal controls case for $0 against a U.S. company for engaging in accounting misconduct including the CEO of the company making misrepresentations to the market concerning $307 million) that the SEC brings this $4.1 million administrative action against Telefonica Brasil (a company with ADRs traded on the NYSE).

The conduct at issue?

You better sit down for this … the company “failed to devise and maintain sufficient internal accounting controls over a hospitality program that the company hosted in connection with the 2014 World Cup and 2013 Confederations Cup” both held in Brazil.

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