This recent post highlighted the $6.5 million enforcement action against 3M based on findings that the company was duped by certain China subsidiary employees.
This recent post discussed how the type of conduct at issue in the 3M enforcement action would seem to fit squarely within prior SEC policy for when an enforcement action would not be warranted.
This post highlights additional issues to consider from the enforcement action.
Timeline
This previous post highlighted the net $60.6 million Foreign Corrupt Practices Act enforcement action against Colombian entities Corficolombiana / Grupo Aval.
This post continues the analysis by highlighting additional issues to consider.
Cash Cow?
In the minds of some (including former FCPA enforcement officials), FCPA enforcement is a convenient cash cow for the U.S. government.
Those who believe this will find support in the Corficolombiana / Grupo Aval enforcement action.
The allegations were basically as follows.
This recent post discussed the approximate $2.5 million FCPA enforcement action against Gartner based on conduct in South Africa – specifically conduct involving the South Africa Revenue Service (“SARS”).
This post highlights additional issues to consider.
Timeline
As stated in Gartner’s most recent annual report (Feb. 16, 2023):
This recent post highlighted the approximate $62 million Foreign Corrupt Practice Act enforcement action against Philips based on conduct in Angola. By resolving another FCPA enforcement action, Philips joined the corporate FCPA repeat offender club.
This post highlights additional issues to consider.
Timeline
As highlighted in this prior post, Philips had been under FCPA scrutiny since at least June 2019.
Thus, from start to finish, the company’s FCPA scrutiny lasted approximately four years.
This recent post highlighted the approximate $8 million FCPA enforcement action against Frank’s International based on conduct in Angola.
This post highlights additional issues to consider.
Timeline
As highlighted in this prior post, in June 2016 Frank’s International disclosed:
