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Five Years Later, Bilfinger Emerges From DPA – Transparency Nil

emerge

As highlighted in this previous post, in 2013 Germany-based Bilfinger resolved a Foreign Corrupt Practices Act enforcement action concerning conduct in Nigeria by agreeing to pay approximately $32 million. The enforcement action was resolved via a three-year deferred prosecution agreement and the company was required to engage a monitor for an 18 month period.

In September 2016, the DPA was extended because, in the words of the DOJ, of “the monitor’s inability to certify compliance with the compliance obligations in the 2013 Agreement after 18 months of monitorship.” In pertinent part the extended DPA stated:

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Friday Roundup

Roundup

Elevate, further to the clustering phenomenon, transparency, dismissed, and incomplete. It’s all here in the Friday roundup.

Elevate

Learning a new topic or elevating your knowledge and practical skills in a topic is not just for formal students in formal educational settings. Professionals in the workplace can also benefit from back to “school” experiences.

For professionals in the FCPA space – or wishing to join the FCPA space – the FCPA Institute serves this objective and has “graduated” approximately 200 hundred diverse professionals since its launch in 2014.

The next FCPA Institute will take place in Nashville on May 3-4th. See here to learn more and to register.

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