Archives: FCPA Jurisdiction

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Law 1778, Colombia’s Latest Attempt at Bringing its Anti-bribery Laws into Compliance with the OECD Anti-bribery Convention

Since being elected in 2010, Colombian President Juan Manuel Santos has been trying to have Colombia become a member of the Organization for Economic Co-operation and Development (OECD). As part of this endeavor, in January 2011, Colombia formally applied to become a participant of the Working Group on Bribery in International Business Transactions (the “Working … Continue Reading

DOJ’s Criminal Division Launches new FCPA Pilot Program

In an effort to enhance its ability to investigate and prosecute Foreign Corrupt Practices Act (FCPA) cases, the Department of Justice’s (DOJ) Criminal Division has launched a new one-year FCPA pilot program effective April 5, 2016. The program has three main goals: Motivate companies to voluntarily self-disclose FCPA-related misconduct Motivate companies to fully cooperate with … Continue Reading

Five Minutes on… Anti-Bribery and Corruption Laws in Europe

Anti-bribery and corruption has been a hot topic in the US for almost 40 years. The topic has historically however received much less attention within Europe. That is now changing as Europe is beginning to catch up and many European countries have already implemented anti-bribery laws much stricter than those in the US. Recent events … Continue Reading

GSK BRIBERY CASE – END OF THE MATTER?

This article was originally published by LexisNexis and is reproduced with permission. GlaxoSmithKline (GSK) has been fined £300 million and five of its employees given suspended prison sentences in China for bribery – but is this the end of the matter? What impact will the verdicts have on other multinational companies conducting business in China? … Continue Reading

Allianz, SEC reach $12.3M agreement in settlement over charges of FCPA Violation

On December 17 2012 Allianz SE, a major German insurance and asset management company, reached a settlement with the Securities and Exchange Commission (SEC) on charges of violating the Foreign Corrupt Practices Act (FCPA). In return for a payment of $12.3M SEC committed to abstain from further inquiries regarding the subject of the procedure – … Continue Reading

Outline of Resource Guide to the U.S. Foreign Corrupt Practices Act (November 14, 2012)

On November 14, 2012, the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) released A Resource Guide to the Foreign Corrupt Practices Act. In its 10 chapters, the Guide provides an overview of the current state of the FCPA as interpreted by the courts, the DOJ and the SEC.  In addition to setting … Continue Reading

District Judge Issues Unprecedented Limitation on FCPA’s Jurisdictional Reach

In an unprecedented blow to the government’s assertion of jurisdiction under the Foreign Corrupt Practices Act (FCPA), United States District Judge Richard Leon, presiding over the so-called Shot Show Sting cases, granted the Rule 29 acquittal motion of Defendant Pankesh Patel on the ground that the government could not establish that jurisdiction over “persons other … Continue Reading

…and counting: 2010 FCPA Enforcement Actions

It certainly seems like 2010 has been a busy year for FCPA enforcement actions. We’ve now tallied all the reported ones (including criminal, civil and SEC administrative actions) that have been resolved  as of December 16th, and the grand tally is…71. Busy indeed. Read the highlights for yourself and kudos to Squire Sanders Anti-Corruption/FCPA Group members Rebekah … Continue Reading
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