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Friday Roundup

Roundup

Cannabis industry, fooled me, questions abound, investigative fees and expenses, survey says, scrutiny alert, and for the reading stack.

It’s all here in the Friday roundup.

Cannabis Industry

This recent FBI public recording states: “As an increasing number of states change their marijuana legislation, the FBI is seeing a public corruption threat emerge in the expanding cannabis industry. States require licenses to grow and sell the drug—opening the possibility for public officials to become susceptible to bribes in exchange for those licenses.”

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The $300,000 Bogus Invoice

fake

[This post is part of a periodic series regarding “old” FCPA enforcement actions]

In 2001, the DOJ filed this criminal information charging Daniel Ray Rothrock (a Vice President of the Cooper Division of Allied Products Corporation with responsibility for international sales) with knowingly and willfully violating the books and records provisions of the Foreign Corrupt Practices Act.

According to the information, Cooper was engaged in the business of manufacturing and selling workover rigs and other oilfield well servicing equipment and one of its customers was RVO Zarubezhneftestroy (Nestro) and entity owned by the Russian government.

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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.

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Friday Roundup

Roundup

Interesting, from the DOJ’s perspective, pay them more, sanctioned, scrutiny update, exit, and for the reading stack. It’s all here in the Friday roundup.

Interesting

As highlighted here, in December 2016 Odebrecht S.A. (a Brazilian holding company) and Braskem S.A. (a Brazil-based petrochemical company in which Odebrecht owns a majority of voting shares) resolved a large FCPA and related enforcement action largely concerning conduct in Brazil including the companies relationships with Petrobras as well as allegations of improper payments in Angola, Argentina, Brazil, Colombia, Dominican Republic, Ecuador, Guatemala, Mexico, Mozambique, Panama, Peru, and Venezuela.

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A Focus On Third Parties

focus

Navex Global recently released this report titled “2018 Third-Party Risk Management Benchmark Report.” I am always a bit skeptical of such survey data given that the results often seem to dovetail nicely with the product offering of the company publishing the survey. Indeed, a final section of the report is titled “About Navex Global’s Third-Party Risk Management Solution.”

Moreover, I often wonder whether such surveys are even statistically valid.

In any event, there were certain survey findings which caught my eye.

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