FCPA Professor Turns 15
In July 2009, FCPA Professor was launched with this simple mission statement.
Fifteen years and approximately 4,500 posts later, FCPA Professor is still here and the mission remains the same. In fact, it is the longest running daily information source about the Foreign Corrupt Practices Act around.
What started out in 2009 as a “blog” has turned into a comprehensive website that has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.” Along the way, FCPA Professor has been named a Top Law Blog for in-house counsel by Corporate Counsel, a Top 25 Business Law Blog by LexisNexis, and a top 100 Legal Blog by the American Bar Association.
What You Need To Know From Q2
This post provides a summary of Foreign Corrupt Practices Act enforcement activity and related developments from the second quarter of 2024. (See here for a summary post from the first quarter of 2024).
DOJ Enforcement (Corporate)
There were no corporate FCPA enforcement actions brought by the DOJ in the second quarter.
DOJ Enforcement (Individual)
There were no individual FCPA enforcement actions brought or announced by the DOJ in the second quarter.
“Compliance Officer” / Dad
Yesterday was Father’s Day and for the ninth straight year I publish this post (with updates) as the “compliance officer” / Dad journey continues and our twin boys turned 16 this year.
Father is just one of my titles when it comes to the boys. Coach and Compliance Officer being a few others. As to the later, Co-Compliance Officer along with my wife is the more accurate title (I wonder what the “Compliance 2.0” [or are we on to 3.0 now] folks would say about this structure)?
Father’s Day is a chance to reflect and to be sure being a Dad has informed my view of many things including compliance. When you really think about, compliance and parenting have a lot in common.
SEC Director Of Enforcement Grewal On Cooperation
Recently Gurbir Grewal (the SEC’s Director of the Division of Enforcement) delivered this speech titled “The Five Principles of Effective Cooperation in SEC Investigations” at a securities law conference.
This post summarizes the speech and provides factual information and rebuttal points relevant to certain topics.
Grewal began as follows:
A Look At Qualcomm’s Corporate Responsibility Report
In 2016, Qualcomm resolved a Foreign Corrupt Practices Act enforcement action (see here) based on alleged improper hiring and other practices in China.
In resolving the matter, Qualcomm agreed to cease and desist from committing or causing any future FCPA violations (a common resolution clause in SEC administrative actions).
Reading the Corporate Responsibility Report of a company that (relatively) recently resolved an FCPA enforcement action was interesting.
Recently, Qualcomm released a “Corporate Responsibility Report” and set forth below are the FCPA or related portions.