Top Menu

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

Issues To Consider From The Westport Fuel Systems Enforcement Action

Issues

This prior post highlighted the SEC’s recent $4 million Foreign Corrupt Practices Act enforcement action against Westport Fuel Systems and a former executive officer (Nancy Gougarty). This post continues the analysis by highlighting additional issues to consider.

Just the Third

Westport Fuel Systems is a Canadian company with shares listed on a U.S. exchange. The enforcement action is believed to be just the third enforcement action in the FCPA’s 40+ year history against a Canadian company. The first enforcement action against a Canadian company was Nordion (2016 – see here and here for prior posts). The second enforcement action against a Canadian company was Kinross Gold (2018 – see here and here for prior posts).

Continue Reading

Issues To Consider From The Quad/Graphics Enforcement Action

Issues

This previous post highlighted the SEC’s recent $10 million Foreign Corrupt Practices Act enforcement action against Quad/Graphics and this post continues the analysis by highlighting additional issues to consider.

Timeline

As highlighted in this prior post, Quad voluntarily disclosed in April 2016. Thus, from start to finish, the company’s FCPA scrutiny lasted approximately 3.5 years. While this is slightly below the average length of time FCPA scrutiny tends to last in the current era (see here), 3.5 years is still too long for a company that voluntarily disclosed and cooperates to be under FCPA scrutiny.

Continue Reading

Issues To Consider From The Juniper Networks Enforcement Action

Issues

This prior post highlighted the SEC’s $11.7 million Foreign Corrupt Practices Act enforcement action against Juniper Networks. This post continues the analysis by highlighting additional issues to consider.

Timeline

As highlighted in this prior post, Juniper Networks disclosed its FCPA scrutiny in mid-2013. Thus, from start to finish the company’s FCPA scrutiny lasted an unconscionable six years.

Continue Reading

Powered by WordPress. Designed by WooThemes