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Evoqua Water Technologies And Former Executive Resolve Books And Records And Internal Controls Matter

evoqua

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 involves Evoqua Water Technologies Corp. and Imran Parekh (a former division-level finance director at the company).

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China Based Issuer Resolves Books And Records And Internal Controls Matter

Cloopen

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 involves Cloopen Group Holding Limited. Cloopen (a Cayman Islands corporation headquartered in China) is a provider of cloud-based communication products and services. As stated by the SEC: “Cloopen does not operate in the United States and has no employees based in the United States. However, because Cloopen has American depositary shares that traded on the NYSE, it was required to file periodic reports” with the SEC.

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UAE Company Resolves Books And Records And Internal Controls Case

Brooge

With the calendar year end fast approaching, the SEC continues to crank out non-FCPA, 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.

The latest example concerns Brooge Energy Limited – a company with its principal executive office located in Dubai, United Arab Emirates which owns and operates an oil storage facility in the UAE.

In summary fashion, this administrative order finds:

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Disclosure Deficiencies Lead To Books And Records And Internal Controls Violations

mallinck.jfif

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 Mallinckrodt plc (an Ireland incorporated and Ireland based pharmaceutical company with shares traded on the New York Stock Exchange during the time period relevant to the enforcement action).

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Royal Bank Of Canada Resolves Books And Records And Internal Controls Enforcement Action

RBC

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 Royal Bank of Canada (RBC) a Canadian chartered bank with shares listed on the New York Stock Exchange.

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