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Friday Roundup


DOJ seeks legislative changes, a focus on FCPA Inc., credit ratings, across the pond, scrutiny update, and for the reading stack.

It’s all here in the Friday Roundup

DOJ Seeks Legislative Changes

The DOJ’s efforts to eradicate corruption and bribery is broader than just Foreign Corrupt Practices Act enforcement and includes: “public integrity prosecutions, bribery prosecutions, prosecutions of taxpayers who seek to conceal foreign accounts, money laundering prosecutions, [and its] Kleptocracy Initiative.”

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FCPA Flash – A Conversation With Anthony Mirenda

FCPA Flash

The FCPA Flash podcast provides in an audio format the same fresh, candid, and informed commentary about the Foreign Corrupt Practices Act and related topics as readers have come to expect from the written posts on FCPA Professor.

This FCPA Flash episode is a conversation with Anthony Mirenda (a partner in the Boston office of Foley Hoag). Mirenda recently co-authored an article “Bridging the Cultural Gap in International Arbitrations Arising from FCPA Investigations” that caught my eye because it discusses a seldom explored corner of the general FCPA space.

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Friday Roundup


FCPA trial starts, scrutiny alerts, ripples, and job alert.  It’s all here in the Friday roundup.

FCPA Trial Starts

The DOJ is rarely put in a position to actually prove FCPA offenses.

Sure, there have been some DOJ successes in recent years, but more often than not the DOJ has failed when put to its burden of proof.  See here for the article “What Percentage of DOJ FCPA Losses Is Acceptable?”  See this prior post for the six most recent instances of the DOJ being put to its burden of proof.

Earlier this week, the first criminal FCPA trial since 2012 began in New Jersey.  The defendant is former PetroTiger CEO Joseph Sigelman. For media coverage of the beginning of the trial, see here and here.

As noted by Bloomberg:

“[O]pening arguments confirmed that the government’s case against Sigelman relies heavily on the testimony of the defendant’s former lawyer. Under pressure from the FBI, the lawyer, Gregory Weisman, implicated Sigelman in wrongdoing and then tried to get his former client to incriminate himself during a covertly recorded conversation.

Lead prosecutor Patrick Stokes, who heads the Justice Department’s FCPA unit, told the jury in his opening remarks that Weisman’s testimony—supplemented by surveillance tape of the witness’s encounter with Sigelman in December 2012—would demonstrate that the defendant knew he had broken the law and was afraid of getting caught. At one point during the December 2012 conversation, Sigelman demanded that Weisman lift his shirt to show he wasn’t wearing a wire. Weisman complied. Sigelman didn’t notice, however, that the FBI had equipped his former attorney with a “button camera” that captured the entire episode.

Sigelman’s behavior, Stokes told the jury, was “something an innocent man doesn’t do.”

In fact, when viewed in its entirety, the grainy undercover tape is ambiguous. When Weisman informed Sigelman that the FBI was asking questions about their actions in Colombia, Sigelman said: “Whatever this is about, I’m ready to be with you.”

“And I’m with you, but I’m extremely scared,” Weisman responded.

“I don’t think there’s anything to be concerned about,” Sigelman said. “We paid a guy. We paid a consultant. … The point is, this wasn’t a bribe in any way, shape, or form.”

In his opening argument yesterday, Sigelman’s defense attorney, William Burck, a partner with the law firm Quinn Emanuel Urquhart & Sullivan, told the jury: “We want you to see that tape.” Burck indicated that in cross-examining government witnesses, he would show jurors that in its zeal to find corruption, the Justice Department has transformed a series of corporate and personal entanglements into a criminal conspiracy that never existed. If anyone was truly trying to fight corruption at PetroTiger, it was Sigelman, the defense lawyer said. Resentful of Sigelman’s finger-pointing, the company’s board turned the tables and fed information to U.S. prosecutors, making the ex-CEO out to be the villain, Burck added.”

For a main issue in the case (the status of Colombia’s Ecopetrol S.A.) , see this prior post.

For additional coverage of the trial, see here.

Scrutiny Alerts

CBCNews reports:

“[Canadian authorities] are investigating allegations from a whistleblowing accountant at [Toronto Stock Exchanged]-listed mining company MagIndustries that his bosses paid bribes to officials in the Republic of Congo to win approvals tied to a potash mine development in that country. According to newly unsealed court documents, the RCMP’s sensitive and international investigations unit raided the Toronto offices of MagIndustries in January. The company has been developing a $1.5-billion potash mine and processing facility in the West African country for several years. Search warrant materials obtained by CBC News tell a cautionary tale about the company, which is registered in Toronto but controlled by Chinese interests since a takeover in 2011. Those investors and managers are now ensnared in an international police bribery investigation. The RCMP believe four top executives with the company, including CEO Longbo Chen who took over in 2012, ignored warnings from Canadian financial advisers and signed off on a string of illegal payments to Congolese officials.”

Bloomberg reports:

“Prosecutors investigating Brazil’s largest corruption scandal say they notified the U.S. Department of Justice of evidence that at least four foreign companies allegedly paid bribes to win Petroleo Brasileiro SA contracts. The allegations are against units or affiliates of Samsung Heavy Industries Co., Skanska AB, AP Moeller-Maersk A/S and Toyo Engineering Corp., Carlos Lima, the senior prosecutor in a nine-member task force, said in an interview. Companies could face charges in Brazil that would restrict local operations as well as possible sanctions under the U.S. Foreign Corrupt Practices Act, he said last week from Curitiba, Brazil.”


Further evidence of FCPA ripples (in other words –  how settlement amounts in an actual FCPA enforcement action are often only a relatively minor component of the overall financial consequences that can result from FCPA scrutiny or enforcement in this new era).

Moody’s Investors Service recently downgraded Key Energy Services.

Among the reasons? According to this release:

“The negative outlook reflects significant ongoing cash expenditures (~$59 million as of Q1-2015) associated with the ongoing Foreign Corrupt Practices Act (FCPA) investigations, the uncertainty around final resolution of these legal matters and the severity of any potential penalties or fines that could further pressure liquidity and credit metrics.”

See here for here for the full article “Foreign Corrupt Practices Act Ripples”

Job Alert

Exactech (a company based in Gainesville, Fla. that develops and markets orthopaedic implant devices, related surgical instruments and biologic materials and services to hospitals and physicians) is looking for a Senior Director of Legal to “to provide legal expertise to guide the company’s actions and transactions with particular emphasis on its Anti-Corruption Compliance program.” See here for the full job description.


A good weekend to all.

Friday Roundup

An invite, ripples, the odd dynamic, and scrutiny alerts and updates.  It’s all here in the Friday roundup.

You Are Invited

King & Spalding is pleased to host Professor Mike Koehler for an informal lunch discussion of his recently published book The Foreign Corrupt Practices Act in a New Era. The conversation and related question-and-answer session will be of interest to anyone seeking a candid and comprehensive discussion of legal and policy issues present in this new era of FCPA enforcement.

The event takes place on Thursday, October 2nd at noon at King & Spalding’s office (1700 Pennsylvania Avenue N.W. Washington, D.C.). There is no charge for this event, but pre-registration is required. If you would like to attend, please send your name and contact information to Sylvia Gates at  For additional information, see here.


My recent article “Foreign Corrupt Practices Act Ripples” highlights how settlement amounts in an actual FCPA enforcement action are often only a relatively minor component of the overall financial consequences that can result from FCPA scrutiny or enforcement in this new era.

Regarding those ripples, Canada’s Globe and Mail reports:

“Hewlett-Packard Co., one of the leading technology suppliers to the Canadian government, is facing a possible 10-year ban on selling products and services to Ottawa in the wake of a high-profile U.S. bribery conviction. The recent criminal conviction, involving bribes paid to Russian government officials, marks the first major test of strict new Canadian integrity rules quietly introduced in March by Public Works and Government Services. Under the new regime, companies face an automatic ban on future government contracts if they or any of their affiliates are convicted of a list of various crimes, such as bribery, even if those crimes occurred outside Canada. “The department is reviewing the recent U.S. court decision regarding HP Russia and is examining the impact of this court decision on our current and future business with HP Canada,” confirmed Alyson Queen, communications director for Public Works Minister Diane Finley. The department will conduct its review “as quickly as possible,” Ms. Queen insisted, adding that the government is “committed to doing business with suppliers who respect the law and act with integrity, including affiliates of suppliers.”

The main point of “Foreign Corrupt Practices Ripples” was described above.  However, the article also states:

“This Article accepts the fact that FCPA scrutiny and enforcement results in many other ripples in this new era. Yet, throughout this Article many questions are posed regarding the legitimacy of certain ripples. Moreover, while it is beyond the focus of this Article, it must nevertheless be highlighted that because of the many ripples of FCPA enforcement, it is important that FCPA enforcement be subjected to meaningful judicial scrutiny and that enforcement actions represent legitimate instances of provable FCPA violations, not merely settlements entered into for reasons of risk aversion. This would seem like an obvious statement. However, the reality is that the majority of corporate FCPA enforcement actions in this new era are based on aggressive and controversial enforcement theories, yet resolved via non-prosecution and deferred prosecution agreements (NPAs / DPAs) not subjected to any meaningful judicial scrutiny by risk-averse business organizations mindful of the adverse consequences of putting the enforcement agencies to its burden of proof in an adversarial proceeding.”

Perhaps Canadian authorities should review this prior post “HP Enforcement Action – Where to Begin.”  The post begins:

“Where to begin? That is the question when analyzing last week’s $108 million Foreign Corrupt Practices Act enforcement action against HP and related entities.  (See here). Should the title of this post have been “The FCPA’s Free-For-All Continues”? Should the title have been “HP = Hocus Pocus” (as in look what the enforcement agencies pulled out their hats this time)? Should the title have been “Warning In-House and Compliance Professionals:  This Post Will Induce Mental Anguish”? Unable to arrive at the best specific title for this post, I simply picked the generic “Where to Begin?” In short, if the HP enforcement action does not leave you troubled as to various aspects of FCPA enforcement you: (i) may not be well-versed in actual FCPA legal authority; (ii) don’t care about the rule of law; or (iii) somehow derive satisfaction from government required transfers of shareholder money to the U.S. treasury regardless of theory. Least there be any misunderstanding, let me begin this post by stating that the enforcement actions against HP Poland, HP Russia and HP Mexico allege bad conduct by certain individuals –  a “small fraction of HP’s global workforce” to use the exact words of the DOJ. As to that “small fraction,” those individuals should be held accountable for their actions by relevant law enforcement authorities. However, as to the actual defendants charged in the enforcement actions – HP Russia, HP Poland and HP Mexico in the DOJ actions – and HP in the SEC administrative proceeding – there are actual legal elements that must be met and there is also prior enforcement agency guidance that ought to be followed.  The entire credibility and legitimacy of the DOJ and SEC’s FCPA enforcement programs depend on these two basics points.”

The Odd Dynamic

I have consistently stated (see here for the most recent iteration) that, based on recent judicial decisions, an odd dynamic exists between application of Dodd-Frank’s anti-retaliation provisions and Dodd-Frank’s whistleblower bounty provisions. As noted in the recent post concerning the Second Circuit’s decision in Liu Meng-Lin v. Siemens, courts have held that the former provisions lack extraterritorial effect while acknowledging that a foreign national could receive a bounty under the whistleblower provisions.

The odd dynamic is front-and-center in the SEC’s recent announcement of “an expected award of more than $30 million to a whistleblower who provided key original information that led to a successful SEC enforcement action.”  According to the release,  “the award will be the largest made by the SEC’s whistleblower program to date and the fourth award to a whistleblower living in a foreign country, demonstrating the program’s international reach.”

In the release, Sean McKessy, Chief of the SEC’s Office of the Whistleblower states:

“This award of more than $30 million shows the international breadth of our whistleblower program as we effectively utilize valuable tips from anyone, anywhere to bring wrongdoers to justice.  Whistleblowers from all over the world should feel similarly incentivized to come forward with credible information about potential violations of the U.S. securities laws.”

Regarding the odd dynamic, the SEC’s order states:

“We believe an award payment is appropriate here notwithstanding the existence of certain extraterritorial aspects of Claimant’s application. See generally Morrison v. Nat’l Austl. Bank Ltd., 561 U.S. 247, 266 (2010) (discussing analytical framework for determining whether an application of a statutory provision that involves certain foreign aspects is an extraterritorial or domestic application of the provision; explaining that it is a domestic application of the provision if the particular aspect that is the “focus of congressional concern” has a sufficient U.S. territorial nexus); European Community v. RJR Nabisco, Inc., F.3d , 2014 WL 1613878, *10 (2d Cir. Apr. 23, 2014) (applying Morrison framework and finding that “[i]f domestic conduct satisfies every essential element to prove a violation of a United States statute that does not apply extraterritorially, that statute is violated even if some further conduct contributing to the violation occurred outside the United States.”). In our view, there is a sufficient U.S.  territorial nexus whenever a claimant’s information leads to the successful enforcement of a covered action brought in the United States, concerning violations of the U.S. securities laws, by the Commission, the U.S. regulatory agency with enforcement authority for such violations.  When these key territorial connections exist, it makes no difference whether, for example, the claimant was a foreign national, the claimant resides overseas, the information was submitted from overseas, or the misconduct comprising the U.S. securities law violation occurred entirely overseas. We believe this approach best effectuates the clear Congressional purpose underlying the award program, which was to further the effective enforcement of the U.S. securities laws by encouraging individuals with knowledge of violations of these U.S. laws to voluntarily provide that information to the Commission. See S. Rep. No. 111-176 at 110 (2010) (“to motivate those with inside knowledge to come forward and assist the Government to identify and prosecute persons who have violated the securities laws ….”). Finally, although we recognize that the Court of Appeals for the Second Circuit recently held that there was an insufficient territorial nexus for the anti-retaliation protections of Section 21F(h) to apply to a foreign whistleblower who experienced employment retaliation overseas after making certain reports about his foreign employer, Liu v. Siemens, F.3d , 2014 WL 3953672 (2d Cir. Aug. 14, 2014), we do not findthat decision controlling here; the whistleblower award provisions have a different Congressional focus than the anti-retaliation provisions, which are generally focused on preventing retaliatory employment actions and protecting the employment relationship.”

Scrutiny Alerts and Updates

BHP Billiton

In its most recent annual report the company stated:

“As previously disclosed, BHP Billiton received requests for information in August 2009 from the US Securities and Exchange Commission (SEC). Following that request, the Group commenced an internal investigation and disclosed to relevant authorities evidence that it has uncovered regarding possible violations of applicable anticorruption laws involving interactions with government officials. The issues relate primarily to matters in connection with previously terminated exploration and development efforts, as well as hospitality provided as part of the Company’s sponsorship of the 2008 Beijing Olympics. The Group is currently discussing a potential resolution of the matter. As has been publicly reported, the Australian Federal Police has indicated that it has commenced an investigation and the Group continues to fully cooperate with the relevant authorities. In light of the continuing nature of the investigations, it is not appropriate at this stage for BHP Billiton to predict outcomes.”

General Cable Corp.

General Cable Corporation (a Kentucky-based company involved in the development, design, manufacture, marketing and distribution of copper, aluminum and fiber optic wire and cable products and systems for the energy, industrial, specialty, construction and communications markets) recently disclosed:

“We have been reviewing, with the assistance of external counsel, certain commission payments involving sales to customers of our subsidiary in Angola. The review has focused upon payment practices with respect to employees of public utility companies, use of agents in connection with such payment practices, and the manner in which the payments were reflected on our books and records. We have determined at this time that certain employees in our Portugal and Angola subsidiaries directly and indirectly made payments at various times from 2002 through 2013 to officials of Angola government owned public utilities that raise concerns under the FCPA and possibly under the laws of other jurisdictions. We also have been reviewing, with the assistance of external counsel, our use and payment of agents in connection with our Thailand and India operations, which may have implications under the FCPA. We have voluntarily disclosed these matters to the SEC and the United States Department of Justice (“DOJ”) and have provided them with additional information at their request. The SEC and DOJ inquiries into these matters are ongoing. We continue to cooperate with the DOJ and the SEC with respect to these matters. We are implementing a screening process relating to sales agents that we use outside of the United States, including, among other things, a review of the agreements under which they were retained and a risk-based assessment of such agents to determine the scope of due diligence measures to be performed by a third-party investigative firm. However, this screening process may not be effective in preventing future payments or other activities that may raise concerns under the FCPA or other laws. At this time, we are unable to predict the nature of any action that may be taken by the DOJ or SEC or any remedies these agencies may pursue as a result of such actions. Any determination that our operations or activities are not in compliance with existing laws or regulations could result in the imposition of substantial fines, civil and criminal penalties, and equitable remedies, including disgorgement and injunctive relief. Because our review regarding commission payment practices and our use and payment of agents described above is ongoing, we are unable to predict its duration, scope, results, or consequences. Dispositions of these types of matters can result in modifications to business practices and compliance programs, and in some cases the appointment of a monitor to review future business and practices with the objective of effecting compliance with the FCPA and other applicable laws.”

In the first trading day after the disclosure, the company’s stock dropped 6.4% to 17.74.


As highlighted in this previous post, Brazil based Embraer (one of  the world’s largest manufacturer of commercial jets with shares traded on the New York Stock Exchange) has been under FCPA scrutiny since 2010.

The Wall Street Journal reports:

“Brazilian authorities have filed a criminal action against eight Embraer employees accusing them of bribing officials in the Dominican Republic in return for a $92 million contract to provide the country’s armed forces with attack planes.”

According to the article:

“[The DOJ and SEC] are also investigating the company’s dealings in the Dominican Republic and elsewhere and have provided their Brazilian counterparts with evidence, according to a request last year for legal assistance from Brazilian prosecutors.


Brazilian prosecutors filed the 31-page complaint in a criminal court in Rio de Janeiro in August, the first step in a criminal prosecution. A spokesman for the Brazilian prosecutors’ office declined to comment on the case.

The complaint alleges that Embraer sales executives agreed to pay a $3.5 million bribe to a retired Dominican Air Force colonel, who then leaned on legislators to approve the deal and a financing agreement between the Dominican Republic and the National Economic and Social Development Bank. The sale was completed and the aircraft were delivered.

The retired colonel, Carlos Piccini Nunez, was serving as the Dominican Republic’s director of special projects for the armed forces in 2008, around the time of the contract negotiations. The contract provided the Dominican Republic with eight Embraer Super Tucanos, turboprop attack support aircraft that have been a darling of air forces in developing countries for their low maintenance and affordability.


The criminal complaint alleges that an Embraer vice president for sales, Eduardo Munhos de Campos, promised to pay the bribe, and that he was assisted in arranging the payments by Orlando Jose Ferreira Neto, another vice president; Embraer regional directors Acir Luiz de Almeida Padilha Jr., Luiz Eduardo Zorzenon Fumagalli and Ricardo Marcelo Bester ; and managers Albert Phillip Close, Luiz Alberto Lage da Fonseca and Eduardo Augusto Fernandes Fagundes.”

Goldman Sachs

The company was recently the focus of this Wall Street Journal article which began:

“A yearslong probe of Goldman Sachs Group’s ties to Libya’s sovereign-wealth fund is focusing on an internship and other perks allegedly offered by the Wall Street bank to win business from the Gadhafi regime, according to people familiar with the matter. The Securities and Exchange Commission is reviewing the New York-based bank’s decision in June 2008 to hire as an intern the brother of Mustafa Zarti, then deputy chief of the Libyan Investment Authority, the people said. The move came after Goldman entered into more than $1 billion worth of trades with the authority, and just as the firm’s relationship with the Libyan fund had begun to sour. The investigators are also reviewing why the brother, Haitem Zarti, was allowed to remain at the firm for almost a year, long after most Wall Street internships last, the people added.”

AgustaWestland / Finmeccanica Related

The Wall Street Journal goes in-depth into the Italian trial of Giuseppe Orsi, former CEO of AgustaWestland – a unit of Finmeccanica Spa, concerning bribery allegations in India. As highlighted in this previous post, Finmeccanica, which is approximately 30% owned by the Italian government, has ADRs registered with the SEC and AgustaWestland does extensive business in the U.S. (see here), including with the U.S. government.


A good weekend to all.

Issues To Consider From The Smith & Wesson Action

This post highlights various issues to consider from this week’s Smith & Wesson Foreign Corrupt Practices Act enforcement action.

Should There Be a Difference?

If the U.S. government uses public taxpayer money to offer or pay a foreign government to induce the government to purchase military and law enforcement products, we construct programs around it and call it “Foreign Military Financing,” “Foreign Military Sales,” etc.

Yet, if a company offers or pays private shareholder money to a representative of a foreign government to induce the government to purchase military and law enforcement programs, the U.S. government calls it bribery.

Should there be a difference?

Either Enforce the FCPA or Don’t

The Department of Justice should either enforce the FCPA or not enforce the FCPA.  Period.  End of story.

The current system in which the DOJ makes opaque, arbitrary, non-reviewable discretionary decisions behind closed doors is contrary to the rule of law.

In the Smith & Wesson action, the SEC alleged that FCPA “violations took place from 2007 through early 2010, when a senior employee and other employees and representatives of Smith & Wesson made, authorized, and offered to make improper payments and/or to provide gifts to foreign officials in an attempt to win contracts to sell firearm products to foreign military and law enforcement departments.”  The culpable individuals were identified as Smith & Wesson’s Vice President of International Sales and its Regional Director of International Sales and the improper conduct concerned business practices in several countries (Pakistan, Indonesia, Turkey, Nepal and Bangladesh).

It’s not every SEC FCPA enforcement action that alleges a multi-year scheme in a number of countries involving a V.P. of International Sales and a Regional Director of International Sales under circumstances in which the company did not voluntarily disclose.

Nevertheless, as previously reported in June, Smith & Wesson disclosed that “the DOJ declined to pursue any FCPA charges against us and closed its investigation.”

Why did the DOJ “decline” to pursue FCPA charges against Smith & Wesson, yet Ralph Lauren (voluntary disclosure of conduct in one country involving one employee of an indirect subsidiary in which the company cooperated) receive a NPA?

Why did the DOJ “decline” to pursue FCPA charges against Smith & Wesson, yet Data Systems & Solutions (conduct in one country involving one employee in which the company cooperated) receive a DPA?

Numerous other examples could be cited as well, but let’s call a spade a spade.  The DOJ’s FCPA enforcement program is not always based on the rule of law, but often opaque, arbitrary, non-reviewable discretionary decisions made behind closed doors.

For instance, as highlighted in this prior post, last September the-then Chief of the DOJ’s FCPA Unit stated at an ABA conference that a large company (he did not provide the company’s name – other than it would be recognizable to the audience) was a “serial reporter” of FCPA issues to the DOJ’s FCPA Unit.  The FCPA Unit Chief said that this company has a “good compliance program and system” in place and does “robust” internal investigations when issues arise.  The FCPA Unit Chief further stated that he and his unit have a “relationship of trust” with this company and its counsel and that “frankly, most of the time” the issue is “not a particularly large issue.”  According to FCPA Unit Chief, this company remediates the issue and then it “goes on its way.”

The following quote (albeit from a different era) is most appropriate:

“We [practitioners] must be able to advise our clients as to whether their conduct violates the law, not whether this year’s crop of administrators is likely to enforce a particular alleged violation.  That would produce, in effect, a government of men and women rather than a government of law.”

There are reasons why the DOJ’s FCPA enforcement program is not as credible as it could and should be and is viewed by many as arbitrary.  The circumstances surrounding Smith & Wesson contribute to these reasons.


In my recent article, “Foreign Corrupt Practices Act Ripples,” I highlight how settlement amounts in an actual FCPA enforcement action are often only a relatively minor component of the overall financial consequences that can result from FCPA scrutiny or enforcement in this new era.

Smith & Wesson is another instructive example of this dynamic (a dynamic that escapes many who write about the FCPA and try to argue that “bribery pays” by measuring settlements amounts vs. bribe payments or business allegedly obtained or retained).

The “Ripples” article talks about the “three buckets of FCPA financial exposure” as follows.

  • Bucket #1 = pre-enforcement action professional fees and expenses
  • Bucket #2 = enforcement action settlement amount
  • Bucket #3 = post-enforcement action professional fees and expenses

In the Smith & Wesson action we know bucket #2 (approximately $2 million).

To my knowledge, Smith & Wesson (like many companies) has not disclosed bucket #1, but it is safe to assume that bucket #1 far exceeded bucket #2, likely by a ratio of at least 2-3 to 1.

As indicated in the earlier post summarizing the SEC’s enforcement action, per the SEC’s order Smith & Wesson has review and reporting obligations to the SEC for a two-year period.  Again, it is safe to assume that bucket #3 will exceed bucket #2.

And then of course there are a variety of negative business consequences that often flow from FCPA scrutiny or enforcement as highlighted in the “Ripples” article.  For instance, in the Smith & Wesson action, the SEC stated, among other things, as follows regarding the company’s “remedial measures” – the company terminated its entire international sales staff; terminated pending international sales transactions; and re-evaluated the markets in which it sought international sales.  Again, it is safe to assume that the financial costs and consequences of these measures far exceeded bucket #2.

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