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Friday Roundup

Roundup

Across the pond, sentenced, unremarkable, and nonsense. It’s all here in the Friday roundup.

Across the Pond

As highlighted in this prior post, in July 2016 the U.K. Serious Fraud Office announced:

“The SFO is conducting a criminal investigation into the activities of Unaoil, its officers, its employees and its agents in connection with suspected offences of bribery, corruption and money laundering.”

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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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Friday Roundup

Roundup

Motion to dismiss filed, guilty plea, role reversal, adequate procedures, for the reading stack, and viewing suggestion. It’s all here in the Friday roundup.

Motion to Dismiss Filed

As highlighted in this prior post, in November 2017 the DOJ announced that Chi Ping Patrick Ho (of Hong Kong, China) and Cheikh Gadio (of Senegal) were criminally charged with conspiring to violate the Foreign Corrupt Practices Act, violating the FCPA, conspiring to commit international money laundering, and committing international money laundering.

Earlier this week, Ho filed this motion to dismiss certain of the FCPA and money laundering charges.

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FCPA Flash – A Conversation With Camilla de Silva (Joint Head of Bribery And Corruption – U.K. Serious Fraud Office)

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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 Camilla de Silva (Joint Head of Bribery and Corruption at the U.K. Serious Fraud Office). During the podcast, de Silva discusses: whether the Bribery Act (including both “hard” and “soft” enforcement) has been successful in achieving its objectives; the SFO’s position on ISO 37001 (it doesn’t have a position); whether the Rolls-Royce enforcement action (see here for a prior post) conflicted with Article 5 of the OECD Convention; and the U.K.’s approach to multi-jurisdictional issues.

See here for a previous FCPA Flash podcast episode with Matthew Wagstaff (Joint Head of Bribery and Corruption at the U.K. Serious Fraud Office).

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Friday Roundup

Roundup

Ironic, scrutiny update, and for the reading stack. It’s all here in the Friday roundup.

Ironic

As highlighted in this previous post, in February 2016 SAP (a German company with American Depository Shares registered with the SEC) resolved a $3.9 million FCPA enforcement action based on conduct in Panama and was ordered to cease and desist from committing or causing any violations and any future violations of the FCPA’s books and records and internal controls case.

Fresh off its 2016 FCPA enforcement action, SAP again became the subject of FCPA scrutiny. (See here for the prior post). Indeed, yesterday the Wall Street Journal reported:

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