Top Menu

Former Microsoft Manager Alleges Widespread Bribery Schemes


As highlighted here, in mid-2019 Microsoft resolved a parallel DOJ and SEC Foreign Corrupt Practices Act enforcement action by agreeing to pay $25.3 million regarding conduct in Hungary, Saudi Arabia, Thailand and Turkey.

Pursuant to a three year DOJ non-prosecution agreement (which still remains in effect), Microsoft agreed (among other things) that should it “learn of any evidence or allegation of conduct that may constitute a violation of the FCPA anti-bribery or accounting provisions had the conduct occurred within the jurisdiction of the United States” to promptly report such evidence or allegation to the Fraud Section and the Office. Pursuant to the SEC administrative order, Microsoft was ordered to “cease and desist from committing or causing any violations and any future violations” of the FCPA’s books and records and internal controls provisions.

In this recent post on a whistleblower platform, Yasser Elabd (a former manger at Microsoft who worked at the company throughout the Middle East and Africa from 1998 to 2018) alleges that Microsoft employees were involved in widespread bribery schemes across several countries in the region.

Continue Reading

Issues To Consider From The Microsoft Enforcement Action


This prior post went in-depth into the recent Microsoft Foreign Corrupt Practices Act enforcement action and this post continues the analysis by highlighting additional issues to consider.


As highlighted in this prior post, Microsoft was reportedly under FCPA scrutiny in various countries since early 2013. Thus, from start to finish the various facets of the company’s FCPA scrutiny lasted an unconscionable 6.5 years. If the DOJ and SEC want their FCPA enforcement programs to be viewed as credible and effective, they must resolve instances of FCPA scrutiny much quicker.

Continue Reading

Microsoft Resolves Long-Standing FCPA Scrutiny By Agreeing To Pay $25.3 Million


Microsoft has been under Foreign Corrupt Practices Act scrutiny since early 2013 (see here for the prior post). Yesterday, the DOJ and SEC announced here and here an aggregate $25.3 million enforcement action against the company and a Hungarian subsidiary concerning conduct in Hungary, Saudi Arabia, Thailand and Turkey.

The enforcement action involved a DOJ component involving a non-prosecution agreement involving MS Hungary in which the entity agreed to pay a $8.8 million criminal penalty and an SEC administrative order against Microsoft finding violations of the FCPA’s books and records and internal controls provisions in which the company agreed, without admitting or denying the SEC’s findings, to pay disgorgement and prejudgment interest of approximately $16.5 million.

Continue Reading

Friday Roundup


Sentenced, just saying, scrutiny alerts and updates, fallout, and what’s the difference? It’s all here in the Friday roundup.


As highlighted in this prior post, earlier this year Frank James Lyon (the owner of Lyon Associates Inc. – a privately held engineering and consulting company headquartered in Hawaii) pleaded guilty to violating the Foreign Corrupt Practices Act (based on things of value provided to officials in the Federated States of Micronesia) as well as paying bribes to an agent of an organization receiving federal funds (based on things of value provided to officials with a Hawaii governmental agency – State Agency).

As highlighted in this DOJ release, Lyon was recently sentenced to 30 months in prison.

Continue Reading

Scrutiny Alerts And Updates

scrutiny alert

This post provides updates on long-standing FCPA scrutiny of the following companies: Fresenius, Noble Corp., Microsoft, Herbalife, Gartner, and TechnipFMC as well as an update from across the pond in the United Kingdom concerning GlaxoSmithKline and  individuals associated with Rolls Royce.


German healthcare firm Fresenius Medical Care AG (a company with shares traded on the NYSE) has been under FCPA scrutiny since 2012 (no that is not a typo). The company recently disclosed:

Continue Reading

Powered by WordPress. Designed by WooThemes