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Friday Roundup

By on August 25, 2017 in CDM Smith, Declination Decisions, FCPA Investigative Costs, Investigative Fees, ISO 37001, Linde, Mahmoud Thiam, Misonix, Och-Ziff Capital, Och-Ziff Capital Management
Roundup

Overhead at the town hall meeting, sentenced, investigative fees, “fake” FCPA news, fairly obvious, hook-line-and-sinker, fore, pardon me for being a stickler, ISO37001 related, and purely speculative and not credible.

It’s all here in the Friday roundup

Overhead at the Town Hall Meeting

I can’t imagine that the FCPA is a frequent topic of discussion at New England town hall meetings. But as highlighted here it was recently a topic of discussion as “the new operator of a popular ski resort in New Hampshire [Och-Ziff]  faced off against concerned residents, some of whom fear the company’s past legal troubles raise doubts about whether it was the right choice to oversee the facility.”

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Checking In On Wal-Mart’s Pre-Enforcement Action Professional Fees And Compliance Enhancements

By on August 18, 2017 in FCPA Investigative Costs, Investigative Fees, Wal-Mart
Wal-Mart

In its recent 2Q FY2018 earnings call presentation Wal-Mart disclosed $12 million in Foreign Corrupt Practices Act and compliance related expenses ($7 million for ongoing investigations and inquiries and $5 million for global compliance program and organizational enhancements). The Q2 expenses of $12 million compare to the following recent quarterly expenses (Q1 FY2018 $16 million; Q4 FY2017 $17 million; Q3  FY2017 $29 million; Q2 FY 2017 $28 million, and Q1 FY2017 $25 million).

Doing the math, Wal-Mart’s 2Q FY2018 FCPA and compliance-related costs is approximately $195,000 per working day.

Over the past 5 years, I have tracked Wal-Mart’s quarterly disclosed pre-enforcement action professional fees and expenses. While some pundits ridiculed me for doing so, it quickly caught on as the popular thing to do.

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Is Cognizant Technology “Boiling The Ocean”?

By on March 3, 2017 in Cognizant Technology Solutions, FCPA Investigative Costs, Investigative Fees
Boiling the Ocean

This prior post highlighted the Foreign Corrupt Practices Act scrutiny of Cognizant Technology Solutions first disclosed in late September 2016. This post discussed how the company’s FCPA scrutiny presented an interesting, albeit early, FCPA case study as to the FCPA’s many “ripples.” (See here for the article “FCPA Ripples“).

The case study has become all the more interesting given that Cognizant recently disclosed: “in 2016, we incurred $27 million in costs related to the FCPA investigation and related lawsuits. We expect to continue to incur expenses related to these matters in 2017 and future periods.”

The question ought to be asked: is Cognizant “boiling the ocean”?

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Friday Roundup

By on February 24, 2017 in Dmitry Firtash, Extradition, FCPA Investigative Costs, Frank’s International, Graña y Montero S.A.A., Investigative Fees, Lennox International, McDermott International, Resource Extraction Disclosure
Roundup

Firtash extradition, scrutiny alerts and updates, spot-on observation, and refreshing words. It’s all here in the Friday roundup.

Firtash Extradition

In April 2014, the DOJ announced the unsealing of a criminal indictment charging six individuals “with participating in an alleged international racketeering conspiracy involving bribes of state and central government officials in India to allow the mining of titanium minerals.” (See here for the prior post).

Among those charged was Dmitry Firtash, a high-profile Ukrainian businessman.

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Checking In On Wal-Mart’s FCPA And Compliance-Related Expenses

By on February 23, 2017 in FCPA Investigative Costs, Investigative Fees, Wal-Mart
Wal-Mart

In its recent 4Q FY2017 earnings call presentation Wal-Mart disclosed $17 million in Foreign Corrupt Practices Act and compliance related expenses ($12 million for ongoing investigations and inquiries and $5 million for global compliance program and organizational enhancements). The Q4 expenses of $17 million compare to Q3 expenses of $29 million, Q2 expenses of $28 million and Q1 expenses of $25 million.

Doing the math, Wal-Mart’s 4Q FCPA and compliance-related costs is approximately $275,000 per working day.

Over the past approximate 5 years, I have tracked Wal-Mart’s quarterly disclosed pre-enforcement action professional fees and expenses.

While some pundits have ridiculed me for doing so, it quickly caught on as the popular thing to do.

Continue Reading

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