A U.K. First
History was made in the U.K. today when Robert John Dougall, a former DePuy executive, pleaded guilty to conspiring with other “to make corrupt payments and/or give other inducements” to “medical...
View ArticleFacilitating Payments or Bribes?
In Greece, it’s the “little envelopes” that affect everyone from “hospital patients to fishmongers.” (see here for the Wall Street Journal story). In India, it’s needing to “string up some wire and get...
View ArticleMore On Alliance One and Universal
Earlier this month (see here) the DOJ and SEC announced FCPA enforcement actions against tobacco companies – Alliance One International, Inc. and Universal Corporation. Both the DOJ (here) and the SEC...
View ArticleJohnson & Johnson Enforcement Action Focuses on Health Care Providers As...
That was quite the 72-hour period for FCPA enforcement last week. On Wednesday, it was JGC Corporation of Japan ($218.8 million in criminal fines). On Thursday, it was Comverse Technologies ($2.8...
View ArticleComverse Technology … Is It Really That Simple?
Question: “If you did not have the choice of deferred or non prosecution agreements, what would happen to the number of FCPA settlements every year. Answer by Mark Mendelsohn, former FCPA chief DOJ:...
View Article"Foreign Official" Limbo – The Bar Has Been Lowered
It’s Friday, so let’s get this started with some music. The previous “limbo low” for an otherwise commercial enterprise to be deemed an “instrumentality” of a foreign government, and thus employees of...
View ArticleNext Up – Smith & Nephew
[A new job has been posted to the Jobs Board – see here. Both job seekers and organizations seeking to hire individuals with FCPA or related experience will benefit from a wide selection of job...
View ArticleEdmonds Pleads Guilty As Trial Nears
The Department of Justice would like for all to believe that its plea agreements represent acknowledgment of the legitimacy of its enforcement theories including as to “foreign official.” A prior...
View ArticleAn Obscure Enforcement Action
[This post is part of a periodic series regarding “old” FCPA enforcement actions] In 1993, the DOJ brought a Foreign Corrupt Practices Act enforcement action against American Totalisator Company...
View ArticleNext Up – Stryker
First it was Johnson & Johnson (see here – $70 million in combined fines and penalties in April 2011). Then it was Smith & Nephew (see here – $22 million in combined fines and penalties in...
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