SEC Brings FCPA Enforcement Action Against Former Executive Of Harris Corp’s...
As highlighted in this prior post, in April 2011 Harris Corporation completed an acquisition of Carefx and in the process acquired its subsidiaries including Carefx China. In connection with its...
View ArticleCircling Back On The Ping / Harris Corp. Matter
This September 15th post regarding the SEC’s enforcement action against Jun Ping Zhang (the former Chairman and CEO of CareFx China, a dissolved Chinese subsidiary of Harris Corp) noted that the SEC,...
View ArticleThe First Time Baker Hughes Resolved An FCPA Enforcement Action
[This post is part of a periodic series regarding “old” FCPA enforcement actions] As highlighted in this prior post, in 2001 KPMG Siddharta Siddharta & Harsono (KPMG-SSH) and Sonny Harsono resolved...
View ArticleFCPA And Then Some As Alere Resolves SEC Enforcement Action
One instance of Foreign Corrupt Practices Act scrutiny that has attracted significant investor interest over the past few years (because it occurred in the context of an M&A transaction) involved...
View ArticleRoundup Of Scrutiny Alerts And Updates
Add some to the list, take a few off, future settlement, continuing to seemingly “boil the ocean,” and monitor costs. This time of year is heavy on annual reports and other corporate disclosures and...
View ArticleCanada-Based Kinross Gold Corp. Resolves Approximate $1 Million SEC Action...
Silly you for believing certain commentator hype that the Trump SEC would stop enforcing the Foreign Corrupt Practices Act or for thinking that the general lull in SEC corporate enforcement during the...
View ArticleDun & Bradstreet Resolves $9.2 Million Enforcement Action Based On Conduct Of...
As highlighted in this prior post, over six years ago Dun & Bradstreet (a leading source of commercial information and insight on businesses) announced that it was under Foreign Corrupt Practices...
View ArticleBeam Pours $8.2 Million Into The Treasury And Becomes The Latest Alcoholic...
First it was alcoholic beverage company Diageo based on conduct in India and elsewhere (see here). Then it was alcoholic beverage company ABInBev based on conduct in India (see here). Yesterday, the...
View ArticleDeputy Assistant AG Miner On M&A Issues, The DOJ’s Opinion Procedure Program,...
As highlighted in this prior post, while in private practice Matthew Miner criticized the “Yates Memo,” DOJ transparency, the deficiencies of DOJ guidance as a solution in the FCPA space, and the...
View ArticleFriday Roundup
Scrutiny alerts and updates, charged, it needs to stop, and my answer. It’s all here in the Friday roundup. Scrutiny Alerts and Updates Plantronics/Polycom In March 2018, Plantronics (an audio...
View ArticleDeputy Assistant Attorney General Matthew Miner On A Variety Of FCPA Issues...
Yesterday, Deputy Assistant AG Matt Miner delivered this speech. It touched upon a number of Foreign Corrupt Practices Act issues including: the DOJ’s Corporate Enforcement Policy, voluntary...
View ArticleDOJ’s Cronan On The “Importance Of Law Enforcement And Private Industry...
Yesterday, DOJ Principal Deputy Assistant Attorney General John Cronan delivered this speech “about the importance of law enforcement and private industry working together in pursuit of common, shared...
View ArticleNext Up – MTS Resolves $850 Million FCPA Enforcement Action
First it was Netherlands-based VimpelCom which resolved a net $398 million FCPA enforcement action in February 2016 for bribing an alleged Uzbekistan telecom official (see here and here for prior...
View ArticleA Look At The Raytheon – United Technologies Merger Through An FCPA Lens
A few days ago Raytheon Company and United Technologies Corporation announced entry “into an agreement to combine in an all-stock merger of equals.” The merger was unanimously approved by the Boards of...
View ArticleDeputy Assistant Attorney General Matthew Miner On ….
Recently Deputy Assistant Attorney General Matthew Miner delivered this speech at an American Bar Association event in Prague. During the speech, Miner touched upon international cooperation; the DOJ’s...
View ArticleFriday Roundup
Quotable, sentenced, scrutiny updates, dismissed and for the reading stack. It’s all here in the Friday roundup. Quotable In a recent Corporate Crime Reporter interview, former DOJ FCPA prosecutor...
View ArticleDOJ Deputy Assistant Attorney General Miner On “The Two Primary Goals Of...
It’s mid-September which means a few things: the days are getting shorter, the trees are beginning to show color, and DOJ and SEC enforcement officials are on the speaking circuit. Earlier this week it...
View ArticleCardinal Health Resolves $8.8 Million Enforcement Action Based On A Former...
Last Friday the SEC announced that Cardinal Health Inc. agreed to pay $8.8 million to resolve a Foreign Corrupt Practices Act enforcement action. The action is based on a Cardinal entity (acquired in...
View ArticleIssues To Consider From The Cardinal Health Enforcement Action
This recent post highlighted the SEC’s $8.8 million Foreign Corrupt Practices Act enforcement action against Cardinal Health. This post continues the analysis by highlighting additional issues to...
View ArticleUsing An Asset Purchase Transaction Structure To Mitigate FCPA Risk
This post is authored by Foley & Lardner attorneys David Simon, Rohan Virginkar, James Peterson, Kristen Maryn and Stephanie Cash. Experienced practitioners and dealmakers understand there may be...
View Article