Top Menu

Issues To Consider From The Telefonica Brasil Enforcement Action

Issues

This previous post went in-depth into the recent $4.1 million FCPA enforcement action against Telefonica Brasil and this post continues the analysis by highlighting additional issues to consider.

What Is The U.S. Interest?

According to the SEC, Telefonica Brasil (a subsidiary of Spanish multinational Telefonica S.A. and the largest telecom company in Brazil with 34,000 employees and $14 billion in revenue)¬†purchased 1,860 World Cup tickets for a total of approximately $5.1 million “for relationship-building activities with strategic audiences.”

Continue Reading

Issues To Consider From The Fresenius Enforcement Action

Issues

This previous post went in-depth into the approximate $232 million Fresenius FCPA enforcement action and this post continues the analysis by highlighting additional issues to consider.

Timeline

As highlighted in this prior post, Fresenius disclosed its FCPA scrutiny in August 2012. Thus from start to finish, its FCPA scrutiny lasted an unconscionable 6.5 years.

Continue Reading

Issues To Consider From The MTS Enforcement Action

Issues

This previous post went in-depth into the recent Foreign Corrupt Practices Act enforcement action against Russia-based MTS for bribing alleged Uzbekistan telecom officials. As highlighted in this prior post, the overall $850 million FCPA settlement amount is the largest in history.

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

Timeline

Continue Reading

The Many Issues To Consider From The Cognizant Technology Enforcement Action

Issues

Previous posts here and here highlighted the recent Foreign Corrupt Practices Act enforcement action against Cognizant Technology Solutions and two of its former executives.

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

Timeline

As highlighted in this prior post, Cognizant disclosed its FCPA scrutiny in a September 2016 SEC filing. Thus from start to finish, Cognizant’s FCPA scrutiny lasted approximately 2.5 years. While 2.5 years is shorter than recent medians of over 4 years (see here), 2.5 years is still too long for FCPA scrutiny to last.

Continue Reading

Issues To Consider From Recent Enforcement Actions

Issues

Previous posts here and here highlighted the late December 2018 Foreign Corrupt Practices Act enforcement actions against Eletrobras and Polycom. This post continues the analysis by highlighting additional issues to consider.

Timelines

As highlighted in this previous post, in June 2015 it was reported that Eletrobras hired a law firm to investigate FCPA issues. Thus, the company’s FCPA scrutiny appears to have lasted approximately 3.5 years. Once again, if the SEC wants its FCPA enforcement program to be viewed as legitimate and credible, it must resolve instances of FCPA scrutiny much quicker.

Continue Reading

Powered by WordPress. Designed by WooThemes