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Former Director of Global Compliance Analytics At Pfizer Files Civil Complaint Against Company Based On Reporting Alleged FCPA Issues


In 2012 Pfizer resolved a $60 million Foreign Corrupt Practices Act action concerning conduct in Bulgaria, China, Croatia, Czech Republic, Italy, Kazakhstan, Russia, and Serbia. (See here).

Beginning in 2019, Pfizer disclosed new FCPA scrutiny.

Pfizer disclosed additional FCPA scrutiny in 2020.

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Law Firm Claims That The Flutter International Enforcement Action Was “Supported” By A Whistleblower Complaint


Earlier this year, the SEC announced a $4 million FCPA enforcement action against Flutter International (a company headquartered in Ireland) – the successor in interest to The Stars Group (a company that was headquartered in Canada) – based on the finding that the “Company paid approximately $8.9 million to consultants in Russia in support of the Company’s operations and its efforts to have poker legalized in that country.” (See here for the prior post).

The SEC’s order stated:

“By at least 2016, the Company’s Board undertook a review of whether the Company, any of its subsidiaries, or any of its personnel had made improper payments, directly or through external consultants, to government officials in certain foreign jurisdictions. As a result of this review, the Company voluntarily contacted the Commission and other U.S. and Canadian regulators …”.

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Record $279 Million Whistleblower Award Made In Connection With Ericsson FCPA Matter – Even Though The Information Was Provided After The SEC Had Already Opened An Investigation Of The Company


According to this recent Wall Street Journal article:

“The record $279 million whistleblower award issued by the Securities and Exchange Commission earlier this month stemmed from a bribery case against telecommunications company Ericsson.” (See here for the prior post about the 2019 enforcement action).

Even though the SEC’s whistleblower award is highly redacted, the few portions that are readable are interesting.

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SEC Commissioner Peirce: “The SEC Once Again Has Sat Down At The Gaming Console To Play Its New Favorite Game “Corporate Manager”


Last week, the SEC announced that Activision Blizzard Inc. (a video game development and publishing company) “agreed to pay $35 million to settle charges that it failed to maintain disclosure controls and procedures to ensure that the company could assess whether its disclosures pertaining to its workforce were adequate.”

The SEC order also found that the company “violated an SEC whistleblower protection rule.”

In summary fashion, the SEC order finds:

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Friday Roundup


Whistleblower award, a non-FCPA, FCPA enforcement action, and an open question.

It’s all here in the Friday roundup.

Whistleblower Award

Recently, the SEC announced “an award of more than $37 million to a whistleblower whose information led to a successful SEC enforcement action and a related action.”

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