Friday Roundup
Funny headline, just plain silly, new SEC FCPA Unit Chief, parallel, scrutiny alerts and updates, company continues to “boil the ocean,” and ISO 37001 related. It’s all here in the Friday Roundup.
Funny Headline
This Global Investigations Review post contains the headline “Former FCPA Unit Chiefs Defend the ‘Revolving Door’”.
That’s funny. I suppose if I moved from a government enforcement attorney position to a multimillion dollar position in FCPA Inc. defending companies against the enforcement climate I helped create, I might defend the practice as well.
Friday Roundup
Overhead at the town hall meeting, sentenced, investigative fees, “fake” FCPA news, fairly obvious, hook-line-and-sinker, fore, pardon me for being a stickler, ISO37001 related, and purely speculative and not credible.
It’s all here in the Friday roundup
Overhead at the Town Hall Meeting
I can’t imagine that the FCPA is a frequent topic of discussion at New England town hall meetings. But as highlighted here it was recently a topic of discussion as “the new operator of a popular ski resort in New Hampshire [Och-Ziff] faced off against concerned residents, some of whom fear the company’s past legal troubles raise doubts about whether it was the right choice to oversee the facility.”
Checking In On Wal-Mart’s Pre-Enforcement Action Professional Fees And Compliance Enhancements
In its recent 2Q FY2018 earnings call presentation Wal-Mart disclosed $12 million in Foreign Corrupt Practices Act and compliance related expenses ($7 million for ongoing investigations and inquiries and $5 million for global compliance program and organizational enhancements). The Q2 expenses of $12 million compare to the following recent quarterly expenses (Q1 FY2018 $16 million; Q4 FY2017 $17 million; Q3 FY2017 $29 million; Q2 FY 2017 $28 million, and Q1 FY2017 $25 million).
Doing the math, Wal-Mart’s 2Q FY2018 FCPA and compliance-related costs is approximately $195,000 per working day.
Over the past 5 years, I have tracked Wal-Mart’s quarterly disclosed pre-enforcement action professional fees and expenses. While some pundits ridiculed me for doing so, it quickly caught on as the popular thing to do.
Checking In On Wal-Mart’s Pre-Enforcement Action Professional Fees And Compliance Enhancements
In its recent 1Q FY2018 earnings call presentation Wal-Mart disclosed $16 million in Foreign Corrupt Practices Act and compliance related expenses ($13 million for ongoing investigations and inquiries and $3 million for global compliance program and organizational enhancements). The Q1 expenses of $16 million compare to the following quarterly expenses in FY2017 (Q4 $17 million, Q3 $29 million, Q2 $ 28 million, Q1 $25 million).
Doing the math, Wal-Mart’s 1Q FY2018 FCPA and compliance-related costs is approximately $260,000 per working day.
Over the past 5 years, I have tracked Wal-Mart’s quarterly disclosed pre-enforcement action professional fees and expenses. While some pundits ridiculed me for doing so, it quickly caught on as the popular thing to do.
Scrutiny Alerts and Updates
Late April or early May is when foreign issuers tend to file Form 20-F’s with the SEC and as highlighted in this post several foreign issuers from Brazil, Peru, the U.K. and South Korea disclosed Foreign Corrupt Practices Act scrutiny.
But first, Cognizant Technology Solutions appears to continue to “boil the ocean” in terms of pre-enforcement action professional fees and expenses and Misonix is hit with a civil lawsuit connected to its FCPA scrutiny.