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Checking In On Leidos


Leidos is a Virginia headquartered information technology, engineering, and science solutions and services company that serves the defense, intelligence, homeland security, civil and health markets. It generates approximatelty 85% of its revenue from U.S. government contracts and its customer list includes the U.S. Department of Defense, the U.S. Intelligence Community, the U.S. Department of Homeland Security, the Federal Aviation Administration, the Department of Veterans Affairs and many other U.S. civilian, state and local government agencies.

Leidos was honored in 2021 as an Ethisphere “World’s Most Ethical Company

As highlighted in this prior post, in February 2022 Leidos disclosed:

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Top Ten Corporate FCPA Settlements

top ten

Set forth below is the current top ten corporate FCPA settlements of all-time actually secured by U.S. law enforcement (in other words net FCPA settlement amounts).

In reviewing this list, it is interesting to note that approximately 15 years ago, the largest FCPA settlement of all-time was $44 million.

Unlike certain other lists, the below list is calculated after consistently accounting for certain credits or deductions in several enforcement actions involving foreign companies and/or related foreign law enforcement actions.

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India’s CBI Files Charge Sheet Against Air India, SAP And IBM Executives


Today’s post is from Sherbir Panag and Ishita Parashar who are both members of the Law Offices of Panag & Babu – India’s largest white collar crimes law firm.

On 4 February 2024, the Central Bureau of Investigation (CBI) – India’s premiere investigation body, filed a charge sheet against the former chairman and managing director of Air India, along with executives from SAP and IBM’s Indian subsidiaries. A charge sheet is the formal conclusion of an investigation, and marks the commencement of a trial. To be clear the charge sheet is reflective of the investigative body’s conclusion on the charges and is not the formal charges that are framed by a court, to which the accused responds.

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“Such Conduct Has Occurred With Respect To Certain Contracts”


Raytheon (which changed its name to RTX in 2003) has been under Foreign Corrupt Practices Act scrutiny for several years.

The company recently disclosed:

“As previously disclosed, in 2019, Raytheon Company received a subpoena from the Securities and Exchange Commission (SEC) seeking information in connection with an investigation into whether there were improper payments made by Raytheon Company, our joint venture known as Thales-Raytheon Systems (TRS), or anyone acting on their behalf, in connection with TRS or Raytheon Company contracts in certain Middle East countries since 2014. In the first quarter of 2020, the DOJ advised Raytheon Company it had opened a parallel criminal investigation. In the third quarter of 2020, Raytheon Company received an additional subpoena from the SEC, seeking information and documents as part of its ongoing investigation. The Company maintains a rigorous anti-corruption compliance program, and continues to cooperate fully with the SEC’s and DOJ’s inquiries, and to examine through our own investigation whether there were any improper payments or any such conduct that was in violation of Raytheon Company policy.

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