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The Top Ten List Of FCPA Disgorgement Amounts

top ten

Everybody, it seems, likes “Top Ten” lists.

This post highlights the top ten corporate FCPA disgorgement (and prejudgment interest) amounts in FCPA history.

The list highlights net FCPA disgorgement (and prejudgment interest) amounts after consistently accounting for (unlike other lists out there) certain credits or deductions in enforcement actions for foreign law enforcement actions or forfeiture amounts paid to the DOJ in a parallel proceeding.

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The Top Ten List Of Corporate FCPA Settlements

top ten

Everybody, it seems, likes “Top Ten” lists.

This post highlights the top ten corporate FCPA settlements of all-time.

It seems odd saying this, but the list (unlike other lists out there) only includes enforcement actions where the corporate defendant was charged with or found to be in violation of the FCPA’s provisions (not other laws). In addition, this list highlights net FCPA settlement amounts after consistently accounting for (unlike other lists out there) certain credits or deductions in several enforcement actions involving foreign companies.

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FCPA Flash – A Conversation With Kara Brockmeyer (Former Chief Of The SEC’s FCPA Unit)

FCPA Flash

The FCPA Flash podcast provides in an audio format the same fresh, candid, and informed commentary about the Foreign Corrupt Practices Act and related topics as readers have come to expect from written posts on FCPA Professor.

This FCPA Flash episode is a conversation with Kara Brockmeyer. Earlier this year, Brockmeyer left the SEC where she served as Chief of the SEC’s FCPA Unit since 2011. In the podcast Brockmeyer (currently a partner at Debevoise & Plimpton): looks back at her time as FCPA Unit Chief including what she views as the most significant matters / trends; discusses a few items that, in her view, are not well-understood or appreciated about the SEC’s FCPA enforcement program; explains theories of enforcement regarding the FCPA’s internal controls provisions; and shares insights regarding the SEC’s whistleblower program relevant to the FCPA.

The podcast is a must listen for any FCPA practitioner or compliance professional.

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Friday Roundup

Roundup

Across the pond, the big picture, ripple, a muddy mess, to FCPA Inc., scrutiny alert, silly and erroneous, misleading, ISO 37001 related, and for the reading stack.

It’s all here in the Friday roundup.

Across the Pond

In this recent speech, David Green (Director of the U.K. Serious Fraud Office) said the U.K. Bribery Act is “regarded as a gold standard internationally” and, as further proof that so-called enforcement competition does exist, he stated:

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The FCPA’s Conversational Waters Are Muddy

muddy water2

There are some issues in the Foreign Corrupt Practices Act space that really should be simple.

For instance, the question “what is an FCPA enforcement action” really should be simple.

However, as highlighted in the article “A Common Language to Remedy Distorted FCPA Enforcement Statistics” various FCPA Inc. participants have adopted (for self-interested reasons perhaps) creative and haphazard counting methods regarding “what is an FCPA enforcement action.” The end result is a muddy conversation about many FCPA enforcement issues and the creative and haphazard counting methods infect the quality and reliability of FCPA enforcement and related statistics of interest to many in the legal and business communities.

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