Across The Pond
The United Kingdom Serious Fraud Office (SFO) announced an enforcement action against Ultra Electronics Holdings Ltd (a British manufacturer of electronic systems for the international defence and aerospace market) in connection with bribery schemes in Oman and Algeria.
As stated in the SFO release, the company “acknowledged accountability for failure to prevent bribery” and a judge “approved a Deferred Prosecution Agreement (DPA) requiring [the company] to pay the penalty, plus £4.8 million in SFO investigation costs. In addition to the financial penalty and costs, the DPA requires the company to meet strict conditions and demonstrate genuine and sustained reform under the scrutiny of the court.”
That Was Vague
Medtronic
Medtronic plc is an American-Irish medical device company with operational and executive headquarters in Minnesota, and legal headquarters in Ireland.
Between 2007 and 2013 Medtronic disclosed FCPA scrutiny concerning its business practices in Greece, Poland, Germany, Turkey, Italy and Malaysia. In mid-2013, Medtronic disclosed: “the SEC and the DOJ both informed the Company that they would be closing their investigations without pursuing any enforcement action or charges against the Company.”
In its most recent quarterly filing, the company disclosed:
Guidance From Canada’s First Remediation / Deferred Prosecution Agreement for Foreign Corruption
A guest post from McCarthy Tetrault LLP attorneys Andrew Matheson, John Boscariol, Robin McKechney, and Adam Dobkin.
The recent Court-approved Remediation Agreement (“RA”), between the Public Prosecution Service of Canada (“PPSC”) and Ultra Electronics Forensic Technology Inc. (“UEFTI”), provides important guidance on procedural and substantive issues for future cases. The agreement (“UEFTI Agreement”) arises from charges against UEFTI for bribing Philippine officials to secure government contracts. This case should be reviewed carefully by any organization considering the potential negotiation of an RA to avoid criminal conviction in any settlement of allegations or charges relating to foreign or domestic corruption, fraud, insider trading, money laundering or other offences within scope of this RA mechanism.[1]
Up North
The Corruption of Foreign Public Officials Act (CFPOA) is Canada’s version of the Foreign Corrupt Practices Act.
This previous post highlighted how a customer of Ultra Electronic Foreign Technology (UEFTI – a company that provides technology and solutions that help law enforcement and border security agencies around the world prevent and solve crime) charged UEFTI with CFPOA offenses.
The customer was Canada’s Royal Canadian Mounted Police (RCMP).
Customer Charges Ultra Electronics Forensic Technology With Crimes
Montreal, Canada based Ultra Electronics Forensic Technology provides technology and solutions that help law enforcement and border security agencies around the world prevent and solve crime.
One of the companies customers is Canada’s Royal Canadian Mounted Police (RCMP).
Recently, the RCMP announced that Ultra Electronics Forensic Technology Inc. (UEFTI) and former four executives (Robert Andrew Walsh, Philip Timothy Heaney, René Bélanger, and Michael McLean) were each charged with bribery and fraud under the Corruption of Foreign Public Officials Act (CFPOA) and the Criminal Code in connection with an investigation by the RCMP into international corruption.