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Friday Roundup

Roundup

Scrutiny alerts and updates, quotable, and for the reading stack. It’s all here in the Friday roundup.

Scrutiny Alerts and Updates

As highlighted in this recent post, Glencore plc, an Anglo–Swiss mining company with headquarters in Switzerland and ADRs traded on a U.S. exchange recently announced that it received a subpoena from the DOJ “to produce documents and other records with respect to compliance with the Foreign Corrupt Practices Act and United States money laundering statutes.  The requested documents relate to the Glencore Group’s business in Nigeria, the Democratic Republic of Congo and Venezuela from 2007 to present.”

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Further Statistics Relevant To Individual Liability Under The FCPA

Statistical Analysis

FCPA Professor frequently publishes statistical information relevant to all matters of Foreign Corrupt Practices Act enforcement including individual enforcement actions. Thus, I took note of Arent Fox’s recent publication with a catchy title “C-Suite at Risk: A Study of Individual Liability Under the FCPA.”

While I find the study professional and well-presented, I do find the study lacking in terms of what I believe are the most important statistics relevant to individual FCPA accountability – statistics that paint a materially different picture from Arent Fox’s conclusion that “the C-Suite has been and will continue to be in the DOJ’s crosshairs.”

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Friday Roundup

Roundup

Scrutiny alert, novice FCPA commentary matters, additional charges, survey says, across the pond, and for the reading stack. It’s all here in the Friday roundup.

Scrutiny Alert

Some companies disclose Foreign Corrupt Practices Act very early and then update the disclosure for years. Other companies have different disclosure practices. Global asset management firm Legg Mason Inc. (a company that has not previously disclosed FCPA scrutiny) recently disclosed:

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Issues To Consider From The Kinross Gold Enforcement Action

Issues

This previous post went in-depth into the recent SEC Foreign Corrupt Practices Act enforcement action against Kinross Gold Corp.

Set forth below are additional issues to consider.

Just the Second

The 2016 enforcement action against Nordion was believed to be the first ever FCPA enforcement action against a Canadian company (see here and here for prior posts). The Kinross enforcement action is believed to be just the second.

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Friday Roundup

Roundup

Scrutiny alerts and updates, just plain silly, #precisionmatters, and for the reading stack. It’s all here in the Friday roundup.

Scrutiny Alerts and Updates

Societe Generale

As highlighted in this 2014 post, Societe Generale, among other companies, has been under FCPA scrutiny regarding its dealings with Libya’s government-run investment fund. The French financial services company recently disclosed:

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