Country Exits Archives - FCPA Professor

Issues To Consider From The Stericycle Enforcement Action

By Mike Koehler on April 27, 2022 in Corrupt Intent, Country Exits, Facilitating Payments, Gray Cloud, Healthcare Providers As Foreign Officials, Internal Controls, Monitor, Obtain or Retain Business, Stericycle, When the Government Doesn’t Pay

This previous post highlighted the recent net $59 million Foreign Corrupt Practices Act enforcement action against Stericycle (an Illinois based medical waste disposal company) for conduct in Brazil, Mexico, and Argentina.

Portions of the alleged conduct were egregious in that an executive of the company’s Latin America division orchestrated the bribery schemes and others associated with the company used “spreadsheets to track the bribe payments.”

Nevertheless, there are several legal and policy issues to consider from the enforcement action.

Timeline

As highlighted in this post, Stericycle disclosed its FCPA scrutiny in mid-2017.

Issues To Consider From The Sargeant Marine Enforcement Action

By Mike Koehler on September 25, 2020 in Country Exits, Obtain or Retain Business, Sargeant Marine, Victims, Voluntary Disclosure

This prior post went in-depth into the recent Foreign Corrupt Practices Act enforcement action against Sargeant Marine Inc. (SMI) and this post continues the analysis by highlighting additional issues to consider.

Why Disclose?

For approximately 15 years, the DOJ has been encouraging business organizations to voluntarily disclose FCPA violations. Yet, time and time again, the DOJ undermines its goal by how it resolves certain enforcement actions.

The SMI matter is the latest example that should cause a board member, audit committee member or others involved in the voluntary disclosure decision to pause.

Issues To Consider From The World Acceptance Corp. Enforcement Action

By Mike Koehler on August 10, 2020 in Collateral Effects, Country Exits, Disgorgement, Gray Cloud, Parent – Subsidiary Issues, Strict Liability, Uncategorized, World Acceptance Corp

This prior post went in-depth into the SEC’s recent $21.7 million Foreign Corrupt Practices Act enforcement action against World Acceptance Corp. (WAC) and this post highlights additional issues to consider.

Timeline

As highlighted in this post, WAC disclosed its FCPA scrutiny in mid-2017. Thus, from start to finish, its scrutiny lasted more than three years. I’ve said it many times, and will continue saying it until the cows come home, if the SEC wants its FCPA enforcement program to be viewed as credible and effective it must resolve instances of FCPA scrutiny much quicker.

Friday Roundup

By Mike Koehler on January 31, 2020 in Armengol Alfonso Cevallas Diaz, Compliance, Country Exits, Declination Decisions

Listening in, guilty plea, marketing the opaque, and machine learning. It’s all here in the Friday roundup.

Listening In

During a recent investor conference call, Cardinal Health executives were discussing how the company continues to evaluate which countries they should be in because “there’s a lot of hidden cost when you’re in a country.”

Company CEO Michael Kaufmann stated:

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Issues To Consider From The Stericycle Enforcement Action

Issues To Consider From The Sargeant Marine Enforcement Action

Issues To Consider From The World Acceptance Corp. Enforcement Action

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