Top Menu

Issues To Consider From The Cardinal Health Enforcement Action

Issues

This recent post highlighted the SEC’s $8.8 million Foreign Corrupt Practices Act enforcement action against Cardinal Health.

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

Timeline

According to the SEC order, “In December 2016, Cardinal voluntarily disclosed the results of its investigation to the Commission staff and subsequently cooperated with its investigation.”

Continue Reading

Like Prior Years, The Gray Cloud Of FCPA Scrutiny Lasted Too Long In 2019

Gray Cloud

This recent post highlighted the origins of corporate Foreign Corrupt Practices Act enforcement actions in 2019.

Continuing with the 2019 FCPA statistical feast, this post follows the chronology of scrutiny to enforcement and highlights one of the most troubling policy issues when it comes to FCPA enforcement.

That is – FCPA scrutiny simply lasts too long. Specifically, as highlighted below, 4.5 years was the approximate median length of time companies that resolved FCPA enforcement actions in 2019 were under scrutiny.

Continue Reading

Issues To Consider From The Ericsson Enforcement Action

Issues

This previous post went in-depth into the Ericsson enforcement action and this post continues the analysis by highlighting additional issues to consider.

Record-Setting

Although there are certain haphazard FCPA top ten lists out there, the Ericsson enforcement action is the largest in FCPA history in terms of actual FCPA settlement amount. (See here for the current top ten list).

Record-Setting?

Even though the Ericsson enforcement action was record-setting, the question arises should it have been record-setting or was it an example of FCPA settlements increasing just because (see here for the prior post)?

Continue Reading

Attorney General Barr Discusses The DOJ’s Cooperation And Coordination With The SEC

barr

The Department of Justice and the Securities and Exchange Commission are separate law enforcement agencies.

However, in certain areas – including the Foreign Corrupt Practices Act – the law enforcement agencies often work together.

In this recent speech, Attorney General William Barr discussed the DOJ’s cooperation and coordination with the SEC.

Continue Reading

Issues To Consider From The Barclays Enforcement Action

Issues

This prior post highlighted the SEC’s recent $6.3 million Foreign Corrupt Practices Act enforcement action against Barclays – the latest FCPA enforcement action focused on alleged improper internship and hiring practices primarily involving the financial services industry.

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

Timeline

In its March 1, 2016 annual report, Barclays disclosed:

Continue Reading

Powered by WordPress. Designed by WooThemes