Ideanomics And Various Individuals Resolve Books And Records And Internal Controls Matter
The Foreign Corrupt Practices Act has always been a law much broader than its name suggests.
Sure, the FCPA contains anti-bribery provisions which concern foreign bribery.
Sure, the FCPA’s books and records and internal controls provisions can be implicated in foreign bribery schemes.
However, the fact remains that most FCPA enforcement actions (that is enforcement actions that charge or find violations of the FCPA’s books and records and internal controls provisions) have nothing to do with foreign bribery. For lack of a better term, these enforcement actions have longed been called non-FCPA, FCPA enforcement actions by this site.
The latest example concerns Ideanomics (a Nevada corporation with principal executive offices in Beijing, China). Since, its inception in 2004, Ideanomics has engaged in a variety of business activities (video-on-demand services, petroleum trading, artificial intelligence, financial technology, and most recently assisting businesses and governments transition their fleets from gas to electric vehicles).