U.S. SECURITIES AND EXCHANGE COMMISSION v. Parker Drilling Company
USA Recht - Civil Action No. 1:13CV461 (E.D. Va., April 16, 2013) The Securities and Exchange Commission today charged Parker Drilling Company, a worldwide drilling services and project management...
View ArticleFCPA: The Art of Strategic Compliance Plan – A Seven Step Process
USA Recht - I recently wrote about my colleague Stephen Martin’s thoughts on having a 1-3-5 year strategic plan for your company’s Foreign Corrupt Practices Act (FCPA) or Bribery Act compliance...
View ArticleFCPA Enforcement: Why Corporations Support DPAs and NPAs
USA Recht - At the recent Dow Jones Global Compliance Symposium, there was a debate royal between Mark Mendelsohn and the FCPA Professor, Mike Koehler, regarding enforcement of the Foreign Corrupt...
View ArticleFCPA: The Saga of MF Global – Don’t Shoot the Messenger, Fire the Chief...
USA Recht - In a post last week on his site, Corruption, Crime and Compliance, Mike Volkov named the Chief Compliance Officer (CCO) his “Person of the Year”. He did so because “There is no other...
View ArticleFCPA: Smith & Nephew DPA: Lessons Learned in Using Distributors
USA Recht - A distributor can be generally defined as a company or individual who purchases a product from an original equipment manufacturer (OEM) and then independently sells that product to an end...
View ArticleFCPA: DPAs and NPAs – Useful Tools to Achieve Compliance
USA Recht - The debate on whether the use of Deferred Prosecution Agreements (DPAs) and Non-Prosecution Agreements (NPAs) has become lively again over the past couple of weeks. Last week, there was a...
View ArticleFCPA: Marc Anthony Redux-We Come Not to Praise Daimler, But to Acknowledge It
USA Recht - Yesterday I discussed the apparent inaction of MF Global’s Board of Directors, when the former Chief Risk Officer left the company after “repeated clashes” with company CEO Jon Corzine,...
View ArticleFCPA: Distributors Should Be Analyzed As Any Other Third Party Representative...
USA Recht - Ed. Note-David Simon is a partner at Foley and Lardner and Bill Athanas is a partner at Waller Lansden Dortch & Davis, LLP. Both have practices which include FCPA compliance. After my...
View ArticleDer lange Arm der US Behörden unter dem Foreign Corrupt Practices Act
USA Recht - Department of Justice, June 28, 2010; Technip S.A. Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $240 Million Criminal Penalty Technip S.A., a global engineering,...
View ArticleFCPA, Code of Conduct – The Cornerstone of a Compliance Program
USA Recht - The cornerstone of a Foreign Corrupt Practices Act (FCPA) compliance program is the US Federal Sentencing Guidelines (FSG). They contain seven (7) basic compliance elements that can be...
View ArticleThe Compliance Integration Risk Assessment
USA Recht - For the want of a nail, the horse was lost. For the want of a horse, the message was lost. For the want of a message, a battle was lost. For the want of a battle, a kingdom was lost. All...
View ArticleFCPA: The HSBC AML Settlement – Lessons Learned for the AML Compliance...
USA Recht - I recently wrote about banks behaving badly. Currently, Exhibit A in that list is HSBC. In December, 2012, the UK banking giant HSBC agreed to pay a fine of $1.92 billion for its...
View ArticleFCPA: The BizJet DPA: Cooperation is the Key
USA Recht - Last week, the Department of Justice (DOJ) announced the resolution of an enforcement action under the Foreign Corrupt Practices Act (FCPA) involving the Tulsa based company, BizJet. The...
View ArticleFCPA: Distributors under the FCPA
USA Recht - If there was ever a question that distributors were covered under the Foreign Corrupt Practices Act (FCPA), in 2012, the Department of Justice (DOJ) and Securities and Exchange Commission...
View ArticleCompliance – die Panalpina Entscheidung
USA Recht - Die Lektüre dieser US-Entscheidung aus dem Jahre 2010 (einem sogenannten Deferred Prosecution Agreement / DPA) ist Pflichtlektüre für all’diejenigen, die sich mit Compliance Programmen...
View ArticleFCPA: The CCO: Co-Equal to the General Counsel in the Eyes of the DOJ
USA Recht - One of the items that the Department of Justice (DOJ) has increasingly focused on in its enforcement actions is the role of the Chief Compliance Officer (CCO) and whether this position has...
View ArticleFCPA: Using History to Create or Rebuild a Compliance Culture
USA Recht - I have wondered how organizations such as Siemens, Alcatel-Lucent or any others that have faced a wide-ranging, global charge of systemic bribery and corruption might change their culture....
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