If you are confused by the above headline, this post serves as a useful reminder that the Foreign Corrupt Practices Act has always been a law much broader than its name suggests because of its books and records and internal controls provisions.
These provisions, among the most generic legal provisions one can find applicable to issuers, can be implicated in a variety of situations – situations that often have nothing to do with foreign bribery.
For instance, recently Baker Hughes disclosed:
Asset recovery, export finance, Och-Ziff related, and for the reading stack.
It’s all here in the Friday roundup.
Asset Recovery
Efforts by the U.S. government to combat foreign corruption are broader than just the Foreign Corrupt Practices Act. For instance, approximately ten years ago the DOJ announced a Kleptocracy Asset Recovery Initiative.
Recently, the DOJ announced:
This post earlier this week told you that there would likely be more Foreign Corrupt Practices Act enforcement this week as the SEC’s fiscal year draws to a close.
Sure enough as late yesterday the SEC announced an approximate $10 million enforcement action against Wisconsin-based printing company Quad/Graphics for “engaging in multiple bribery schemes in Peru and China.”
