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What Will September Bring?

September

September is a great month. The heat and humidity of July and August have largely subsided, evenings are crisp and cool, the leaves begin to change, college football returns to campus, and oh those honeycrisp apples!

As highlighted in this post, historically September has tended to be an active month for FCPA enforcement. Most notably, the SEC’s fiscal year ends on September 30th and while we would like to think that the government does not “close its books” like a business organization at the end of a fiscal year, this most certainly appears to be the case.

As further highlighted, September has also tended to be an active month for enforcement agency speeches as “official Washington” gets back to its business of making rhetoric filled policy speeches.

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Elevate Your FCPA Knowledge At The FCPA Institute – Indianapolis (Sept. 28-29)

Featured Image FCPA Institute

Could someone in your firm or organization benefit from a two-day, active learning experience devoted to the Foreign Corrupt Practices Act?

If so, please consider the FCPA Institute which is next making a stop in Indianapolis on September 28-29 and hosted by Quarles & Brady.

Since 2014, the FCPA Institute has elevated the FCPA knowledge and practical skills of over 100 diverse professionals through active learning and the below video introduces you to the FCPA Institute; how the FCPA Institute is different than other FCPA conferences; the substantive knowledge and practical skills participants will gain by attending the FCPA Institute; and what prior FCPA Institute “graduates” have said about their experience.

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Elevate Your FCPA Knowledge At The FCPA Institute – Indianapolis (Sept. 28-29)

Featured Image FCPA Institute

Could someone in your firm or organization benefit from a two-day, active learning experience devoted to the Foreign Corrupt Practices Act?

If so, please consider the FCPA Institute which is next making a stop in Indianapolis on September 28-29 and hosted by Quarles & Brady.

Since 2014, the FCPA Institute has elevated the FCPA knowledge and practical skills of over 100 diverse professionals through active learning and the below video introduces you to the FCPA Institute; how the FCPA Institute is different than other FCPA conferences; the substantive knowledge and practical skills participants will gain by attending the FCPA Institute; and what prior FCPA Institute “graduates” have said about their experience.

Continue Reading

Elevate Your FCPA Knowledge At The FCPA Institute – Indianapolis (Sept. 28-29)

Featured Image FCPA Institute

Could someone in your firm or organization benefit from a two-day, active learning experience devoted to the Foreign Corrupt Practices Act?

If so, please consider the FCPA Institute which is next making a stop in Indianapolis on September 28-29 and hosted by Quarles & Brady.

Since 2014, the FCPA Institute has elevated the FCPA knowledge and practical skills of over 100 diverse professionals through active learning and the below video introduces you to the FCPA Institute; how the FCPA Institute is different than other FCPA conferences; the substantive knowledge and practical skills participants will gain by attending the FCPA Institute; and what prior FCPA Institute “graduates” have said about their experience.

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Issues To Consider From The Halliburton Enforcement Action

Issues

This prior post went in-depth into last week’s $29.2 million Foreign Corrupt Practices Act enforcement action against Halliburton and this post continues the analysis by highlighting additional issues to consider.

Timeline

Halliburton disclosed to the DOJ / SEC in December 2010 or perhaps early 2011. Regardless of the precise date, Halliburton’s FCPA scrutiny lasted approximately 6.5 years.

If the SEC wants the public to have confidence in its FCPA enforcement program, it must resolve instances of FCPA scrutiny much quicker. Having FCPA scrutiny linger for 6.5 years is inexcusable particularly since Halliburton, in the words of the SEC, “[cooperated] including making foreign witnesses available, compiling financial data and analysis relating to the transactions at issue, and making substantive presentations on key topics at the staff’s request.”

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