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The Need For An FCPA Common Language – Visual Proof

visual proof

These pages have frequently highlighted the need for a Foreign Corrupt Practices Act common language as to the basic question of “what is an FCPA enforcement action?” (See here for the article “A Common Language to Remedy Distorted FCPA Enforcement Statistics” which exposes in detailed fashion distorted FCPA enforcement statistics).

As highlighted in the article, the absence of an FCPA common language has numerous negative effects including infecting nearly all FCPA enforcement statistics.

The most reliable and accurate way to keep FCPA enforcement statistics is by using the “core” approach which focuses on unique instances of FCPA scrutiny. Using this approach, there were 27 corporate FCPA enforcement actions in 2016 that resulted in approximately $2.4 billion in net FCPA settlement amounts (see here).

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Issues To Consider From The JP Morgan Enforcement Action

Issues

This previous post went in-depth into the recent Foreign Corrupt Practices Act enforcement action against JP Morgan based on its alleged improper hiring and internship practices that the U.S. government labeled bribery and corruption

This post continues the analysis by highlighting several additional issues to consider.

Other Internship / Hiring Enforcement Actions

While the JPMorgan hiring and internship enforcement action was the most high-profile based on the settlement amount, it certainly was not the first FCPA enforcement action based on alleged improper internship and hiring practices.

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Friday Roundup

Roundup

Checking in on Wal-Mart, DOJ “declinations,” another installment of as we say not as we do, scrutiny alerts, and cashing in. It’s all here in the Friday roundup.

Wal-Mart

In its recent 2Q FY2017 earnings call presentation Wal-Mart disclosed $28 million in Foreign Corrupt Practices Act and compliance related expenses ($23 million for ongoing investigations and inquiries and $5 million for global compliance program and organizational enhancements). The Q2 expenses of $28 million are higher than the Q1 expenses of $25 million.

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Friday Roundup

Roundup

Scrutiny alerts and updates, sentenced, asset recovery, to FCPA Inc., across the pond, quotable and for the reading stack.

It’s all here in the Friday roundup.

Scrutiny Alerts and Updates

Grupo Televisa

This Wall Street Journal article concerns Grupo Televisa SAB, a Mexican broadcaster with shares traded on the NYSE. According to the article:

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