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

proposal

Including the first time I proposed this concept in 2010, this is the sixth time I have written this general post (see here, here, here, here and here for the previous versions) and 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 manner, the facts the company disclosed and why the enforcement agency did not bring an enforcement action based on those facts.

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Friday Roundup

Roundup

Quotable, scrutiny alerts and updates, and for the reading stack. It’s all here in the Friday roundup.

Quotable

Royal Dutch Shell resolved an FCPA enforcement action in 2010 concerning conduct in Nigeria. At present, the company is under FCPA scrutiny again for its business practices in Nigeria.

During a recent investor conference call, an analyst asked “in light of the various corruption cases that hit the oil sector, which seem to be more and more frequent, is there anything you think needs to be done better at the industry level to deal with violations of the FCPA?”

Royal Dutch CEO Ben van Beurden stated:

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