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Next Up – A $77 Million Enforcement Action Against Credit Suisse

CS

First, it was BNY Mellon Corp. in August 2015 for $14.8 million (see here and here for prior posts). Then, it was Qualcomm in March 2016 for $7.5 million (see here and here for prior posts). Then, it was JPMorgan in November 2016 for $202.6 million (see here, here, and here for prior posts).

Next up in Foreign Corrupt Practices Act enforcement actions (mostly targeting the financial services industry) focusing, in whole or in part, on internship and hiring practices being a form of bribery is Credit Suisse as the DOJ and SEC officially announced today (see here and here) the expected enforcement action (see here).

If you were wondering whether this “scurrilous and hypocritical” form of FCPA enforcement action (as stated by a former SEC Chairman see here) would carry forward to the Trump administration, you now have the answer.

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Friday Roundup

Roundup

“Piling on” roundup, from the docket, across the pond, complete lack of perspective, scrutiny alert, say what, and for the reading stack. It’s all here in the Friday roundup.

“Piling On” Roundup

FCPA Professor has provided the most extensive, real time coverage and commentary of the DOJ’s recent so-called “piling on” policy. See prior posts here, here and here.

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Panasonic Corp. And Related Entity Resolve $280 Million Avionics Industry FCPA Enforcement Action

panasonic

Yesterday, the DOJ and SEC announced (here and here) a parallel Foreign Corrupt Practices Act enforcement action against Japan-based Panasonic Corp.  and a U.S. subsidiary Panasonic Avionics Corp. (PAC).

As stated in the enforcement action, Panasonic was an issuer until April 2013 and again “for a brief period between 2015 and 2016 as a result of a share swap that retriggered Panasonic’s obligation to file its financial statements with the SEC.”

As highlighted in this post, the enforcement action consisted of:

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Dun & Bradstreet Resolves $9.2 Million Enforcement Action Based On Conduct Of Two Indirect Chinese Subsidiaries From 6-12 Years Ago

D&B

As highlighted in this prior post, over six years ago Dun & Bradstreet (a leading source of commercial information and insight on businesses) announced that it was under Foreign Corrupt Practices Act scrutiny concerning conduct in China.

Yesterday, the SEC (Snails-Pace Enforcement Commission) announced that D&B agreed to resolve an FCPA enforcement action by paying approximately $9.2 million to “arising from improper payments made by two Chinese subsidiaries.”

This administrative order states, in summary fashion:

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Various Individuals Associated With Rolls-Royce Criminally Charged In Connection With Kazakhstan – Chinese Pipeline Project

Rolls

As highlighted in prior posts here and here, in January 2017 the DOJ announced a $170 million Foreign Corrupt Practices Act enforcement action against U.K. based Rolls-Royce. The allegations included several generic references to employees at Rolls-Royce and Rolls-Royce Energy Systems (RRESI, an indirect subsidiary located in Ohio) who conspired to cause “to make over $35 million in commission payments to commercial advisors and others, knowing that the commission payments would be used to bribe foreign officials on behalf of Rolls-Royce and RRESI in Thailand, Brazil, Kazakhstan, Azerbaijan, Angola, Iraq and elsewhere, in exchange for foreign officials’ assistance in providing confidential information and awarding contracts to Rolls-Royce, RRESI, and affiliated entities.”

Earlier this week, the DOJ announced an FCPA enforcement action against five individuals based on the same Kazakhstan conduct alleged in the prior corporate action. That is, bribery in connection with an RRESI contract to supply gas turbine units to Asia Gas Pipeline LLC (AGP) for approximately $145 million.

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