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This Week On FCPA Professor

ThisWeekPost

FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.”

Set forth below are the topics discussed this week on FCPA Professor.

In this FCPA Flash podcast episode, Daniel Suleiman (Covington & Burling who previously served as a senior official in the DOJ’s Criminal Division including as Deputy Chief of Staff & Counselor to the Assistant Attorney General) discusses the life cycle of FCPA internal investigations,

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This Week On FCPA Professor

ThisWeekPost

FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.”

Set forth below are the topics discussed this week on FCPA Professor.

This post provides a summary of FCPA enforcement activity and related developments from the third quarter of 2018.

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Issues To Consider From The Stryker Enforcement Action

Issues

This previous post highlighted the SEC’s recent $7.8 million enforcement action against medical device company Stryker.

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

Two Ways to Look at Repeat Offenders

As highlighted in the prior post, Stryker is now in the FCPA repeat offender club. There are two ways to look at certain of the companies on the list.

On the one hand, one could view these companies as corrupt companies without a commitment to compliance who did not learn any lesson from the first time the company resolved an FCPA enforcement action.

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This Week On FCPA Professor

ThisWeekPost

FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.”

Set forth below are the topics discussed this week on FCPA Professor.

As highlighted here, Stryker joined the FCPA repeat offender club as the SEC announced a $7.8 million enforcement action against the medical device company for not having internal accounting controls “sufficient to detect the risk of improper payments in sales of Stryker products in India, China, and Kuwait” and because “Stryker’s India subsidiary failed to maintain complete and accurate books and records.”

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The Top Ten List Of Corporate FCPA Settlements

top ten

With the recent Petrobras enforcement action (see here for the prior post), there is lots of false and misleading information in the public domain regarding the actual FCPA settlement amount (that is the amount of money the DOJ and SEC will actually collect from the enforcement action). The Petrobras FCPA enforcement action is a net approximate $170 million action as clearly evidenced in the government’s documents as well as Petrobras’s own press release.

This post highlights the top ten corporate FCPA settlements of all-time.

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