Checking In On Toyota’s FCPA Scrutiny
As highlighted in this prior post, approximately 5 years ago, Japan-based Toyota Motor Company disclosed as follows.
“In April 2020, Toyota reported possible anti-bribery violations related to a Thai subsidiary to the SEC and the U.S. Department of Justice (“DOJ”), and is cooperating with their investigations. The investigations could result in the imposition of civil or criminal penalties, fines or other sanctions, or litigation by the DOJ or the SEC. Toyota cannot predict the scope, duration or outcome of the matter at this time.”
This prior post foreshadowed Toyota’s potential FCPA scrutiny and this article highlights the civil suit that may have prompted Toyota’s disclosure.
Friday Roundup
A strange scenario, scrutiny alert, and Odebrecht related. It’s all here in the Friday roundup.
A Strange Scenario
FCPA enforcement actions have concerned some interesting family relationships. Husband/Wife as co-defendants. Brother/Sister as co-defendants. Father/Son as co-defendants.
But a wife bribing a husband? To my knowledge, this has never occurred in an FCPA enforcement action.
Until, that is … this week’s FCPA (and related) enforcement action against various individuals in relation to Griffiths Energy International’s bribery scheme involving Chad. (See here for the prior post).
Friday Roundup
Acquitted, scrutiny alert, under scrutiny again, across the pond, and compassionate release. It’s all here in the Friday roundup.
Acquittals
The so-called conventional wisdom in the U.S. is that business organizations under Foreign Corrupt Practices Act scrutiny (particularly publicly-traded corporations) simply can’t put the DOJ (or SEC for that matter) to its burden of proof in an enforcement action because it is too risky and may result in a “death sentence” for the company.
As highlighted in this post, the conventional wisdom is b.s., but the narrative still persists. In other countries however, corporations more frequently put government enforcement agencies to their burdens of proof by making factual and legal arguments.
Friday Roundup
What the ….?, FCPA Scrutiny?, and in settlement talks.
It’s all here in the Friday roundup.
What The ….?
There have been some things written about the Foreign Corrupt Practices Act in recent years that should cause anyone reasonably well informed individual to shake their head in disbelief and ask what the …?
For instance, this piece states: