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

proposal

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

This post highlights a new instance of Foreign Corrupt Practices Act scrutiny involving KT Corporation (a South Korean telephone company) and updates regarding long-standing FCPA scrutiny of Herbalife, World Acceptance Corp., Raytheon, and Stericyle.

KT Corporation

For several years, KT Corp (South Korea’s largest telecom company with shares traded on the New York Stock Exchange) has been under scrutiny by South Korean authorities for, among other things: donations to non-profit foundations at former President Park’s request; making certain donations or gifts to various lawmakers; and alleged improper hiring of college graduates.

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Scrutiny Alerts And Updates

scrutiny alert

This post highlights Foreign Corrupt Practices act and related scrutiny alerts and updates regarding the following companies: International Flavors and Fragrances, Herbalife, Veolia, Stericycle, and Bombardier.

International Flavors and Fragrances

In October 2018, New York based International Flavors and Fragrances (IFF) Inc. acquired Israel-based Frutarom Industries Ltd. (a flavors, savory solutions and natural ingredients company).

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Roundup Of Scrutiny Alerts And Updates

scrutiny alert

Add some to the list, take a few off, future settlement, continuing to seemingly “boil the ocean,” and monitor costs.

This time of year is heavy on annual reports and other corporate disclosures and this post rounds up various scrutiny alerts and updates.

Albemarle Corp.

The North Carolina based chemical company recently disclosed:

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Friday Roundup

Roundup

Issue to ponder, scrutiny alert, laughable, silly, $50 million spent in approximately 9 months, and for the reading stack. It’s all here in the Friday roundup.

Issue to Ponder

If the FCPA and U.K. Bribery Act “have been broadly effective in addressing and remediating corrupt practices within … companies [subject to the laws]” as asserted in this article, then why – generally speaking – is there more (not less) enforcement actions under these laws over time? 

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