This previous post concerned the FCPA enforcement action against Lifecore Biomedical, Inc. (f/k/a Landec Corporation) in connection with alleged Foreign Corrupt Practices Act violations involving wastewater issues in Mexico.
This post highlights additional issues to consider.
Timeline
As highlighted in this prior post, in January 2020 Landec disclosed:
This recent post highlighted the net $218.4 million enforcement action against chemical company Albemarle Corp.
This post highlights additional issues to consider from the enforcement action.
Timeline
As highlighted in this prior post, in February 2018 Albemarle Corp. disclosed scrutiny. Specifically, the company disclosed:
This recent post highlighted the $26.1 million enforcement action against Clear Channel Outdoors based on the conduct of a former indirect, majority-owned Chinese subsidiary (Clear Media Limited).
This post highlights additional issues to consider from the enforcement action.
Timeline
As highlighted here, in April 2018 disclosed FCPA scrutiny.
Thus, from start to finish, Clear Channel’s FCPA scrutiny lasted an unconscionable 5.5 years.
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.
