When under scrutiny for potential Foreign Corrupt Practices Act violations, how does a company prove that it was doing the right thing? The memories of your employees, along with their narratives of what happened will not be persuasive. Sure, interviewing […]
The Foreign Corrupt Practices Act (FCPA) is aimed at preventing bribery of foreign officials. One key part of the FCPA is the books and records provision, which includes the following from 15 U.S.C. § 78m: (2) Every issuer which has […]
Earlier this week, Las Vegas Sands (NYSE:LVS) announced in its 10-K for the year ended December 31, 2010 that it is the subject of an FCPA investigation: On February 9, 2011, LVSC received a subpoena from the Securities and Exchange Commission […]
2010 has been a momentous year for securities enforcement, litigation and compliance issues–and there are still a few days left in 2010 for more crazy stuff to happen! On December 29, 2010, Securities Docket will host its annual “Year in […]
This week I recorded a podcast for the International Association for Asset Recovery (IAAR), which is accessible on the IAAR site. We talked a bit about where financial investigations are going, and how I am using technology to complete these […]
I’ve recently been looking more closely at the Foreign Corrupt Practices Act (FCPA) as I consider the types of services companies will need from independent forensic accountants. This is an area in which government enforcement is skyrocketing, and so there […]
A recent Compliance Week article, An Expensive Lesson on FCPA Compliance [subscription required], provides some valuable insights on the direction that our government is taking with enforcement. Foreign Corrupt Practices Act violations are a huge focus of the feds right […]
The United States Sentencing Guidelines (USSG) continue to make life tough for those in charge of corporate compliance and ethics. Corporate attorneys, both in-house and outside counsel, must ensure that companies are following protocols set for by the USSG. Rightfully, […]
The investigation into bribery allegations at Siemens AG ends with a fine and a charge for illegal profits. The company is paying the equivalent of $284 million in a case that prosecutors have referred to as Europe’s largest bribery investigation […]
