This Week On FCPA Professor
FCPA Professor 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.”
Set forth below are the topics discussed this week on FCPA Professor.
What will September bring – as the month is traditionally an active month for FCPA enforcement? (See here).
What Will September Bring?
September is a great month. The heat and humidity of July and August have largely subsided, evenings are crisp and cool, the leaves begin to change, the kids go back to school, college football returns to campus, and oh those honeycrisp apples!
As highlighted in this post, historically September has tended to be an active month for FCPA enforcement.
Most notably, the SEC’s fiscal year ends on September 30th and while we would like to think that the government does not “close its books” like a business organization at the end of a fiscal year, this most certainly appears to be the case. Indeed SEC Commissioner Hester Peirce has called this September dynamic (which is observable not just in FCPA enforcement actions but other actions as well) as the SEC’s “own version of earnings management.” (See here).
This Week On FCPA Professor
FCPA Professor 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.”
Set forth below are the topics discussed this week on FCPA Professor.
As to the recent enforcement action against 3M in which the company was duped by certain China subsidiary employees who provided travel and entertainment to alleged Chinese officials, this post highlights approximately 30 FCPA enforcement actions regarding alleged improper travel and entertainment of Chinese officials. This post highlights additional issues to consider from the 3M enforcement action. As discussed in this post, per previous SEC policy, there likely would not have been an enforcement action against 3M.
This Week On FCPA Professor
FCPA Professor 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.”
Set forth below are the topics discussed this week on FCPA Professor.
The DOJ is seeking a new FCPA Unit Chief. (See here).
U.K. Serious Fraud Office Drops Two Long-Standing Bribery Investigations
The general equivalent to the Department of Justice in the United Kingdom is the Serious Fraud Office (SFO).
Compared to the DOJ, the SFO does a much better job of keeping the public informed of its investigations.
Recently, the SFO updated its case archive concerning two long-standing bribery investigations involving ENRC Ltd. and Rio Tinto.