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An Accounting Fraud Matter With Some FCPA Sprinkled In

holographic

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

Foreign Corrupt Practice Act issues can be the tip of the iceberg with a company and its executives also engaging in other improper conduct. Such was the case in an enforcement action American Bank Note Holographics and its executive Joshua Cantor.

This 2001 criminal information against Joshua Cantor  (during the relevant time period President or Executive Vice President and General Manager of American Bank Note Holographics, Inc. (ABNH), a subsidiary of American Banknote Corporation) is primarily a securities / accounting fraud matter.

However, Cantor was also charged with count of conspiracy to violate the FCPA’s anti-bribery provisions.

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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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