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Once Again, Rebooting A Long-Standing FCPA Proposal, This Time In The Aftermath Of A Recent Disclosure By Pactiv Evergreen


Including the first time I proposed this concept in 2010, this is the 11th time I have written this general post (see hereherehereherehereherehereherehere and here for the previous versions). Until things change I will keep writing it which means I will probably keep writing this same general post long into the future.

The proposal is this: when a company voluntarily discloses an FCPA internal investigation to the DOJ and/or SEC and when one or both of the enforcement agencies do not bring an enforcement action, have the enforcement agency publicly state, in a thorough and transparent mannerthe facts the company disclosed and why the enforcement agency did not bring an enforcement action based on those facts.

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Scrutiny Alerts And Updates

scrutiny alert

Ormat Technologies

As highlighted here, earlier this year a “short seller” alleged that Ormat Technologies (a Nevada-based geothermal power company with shares traded on the New York Stock Exchange that owns and operates power plants in Kenya, Guadalupe, Guatemala, Honduras and the United States) was “engaged in what we believe to be widespread and systematic acts of international corruption.”

In its most recent quarterly filing, Ormat stated:

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In Connection With Anticipated Initial Public Offering, Company Discloses FCPA Scrutiny


Reynolds Group Holdings Limited is a New Zealand based packaging company that is to be converted to a Delaware corporation and renamed Pactiv Evergreen Inc.

Recently it announced its intention to offer approximately 41 million shares in a U.S. initial public offering.

In this Registration Statement, the company disclosed:

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