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First self-report settlement in Scotland

Posted in Uncategorized

The Scottish Civil Recovery Unit is to recover £5.6 million under Proceeds of Crime legislation after a Scottish drilling company, Abbot Group Limited (“Abbot”), admitted it had benefited from corrupt payments made in connection with a contract entered into by one of its overseas subsidiaries and an overseas oil and gas company. The contract was… Continue Reading

M&S strengthens its anti-bribery controls in India

Posted in Uncategorized

British retail giant Marks & Spencer (M&S) is attaching strict anti-bribery clauses to agreements in India as the company moves ahead with its expansion plans in the country. M&S currently operates 25 stores in India through a 51:49 joint venture agreement with Reliance Retail Limited, a subsidiary of Reliance Industries.  The retail giant is also… Continue Reading

Bribery Act Investigations at Rolls Royce

Posted in Uncategorized

Rolls-Royce, the world’s second largest aircraft engine maker, made a public announcement on the 6 December 2012 that it has provided information to the Serious Fraud Office (SFO) in relation to bribery and corruption activities that have taken place in Indonesia, China and other undisclosed overseas markets involving its intermediaries.  In a statement released through… Continue Reading

Report shows that compliance with OECD Anti-Bribery Convention remains inadequate

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Transparency International has recently published its 8th annual progress report on compliance with the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, adopted in 1997, which requires each signatory country to make foreign bribery a crime. In relation to enforcement, of the 37 signatory countries included in the report, (which… Continue Reading

Judge Hands Down Sentences on Former CCI CEO, Sales Director

Posted in China, Foreign Corrupt Practices Act, Uncategorized

On November 8, 2012, Judge James Selna (C.D. Cal.) sentenced Stuart Carson, former CEO of Control Components Inc. (“CCI”), and his wife, Hong Rose Carson, the company’s former sales director, for their roles in the company’s violation of the FCPA and Travel Act. In 2009, CCI pleaded guilty to a three-count criminal information that charged… Continue Reading

Bribery fears increase as UK businesses encouraged to boost export performance

Posted in Uncategorized

As part of the UK government’s remodelling of the British economy, UK businesses are being encouraged to widen their export base. Given the intransigent economic problems in the Eurozone, traditionally the UK’s biggest export market, there are sound economic reasons for doing so. George Osborne, the Chancellor of the Exchequer, has championed the role of… Continue Reading

Monthly China Anticorruption Update Report-September 2012

Posted in Uncategorized

The most recent FCPA and anticorruption enforcement developments involving the People’s Republic of China (PRC) are summarized below.  Thanks as always to Squire Sanders Shanghai Office for monitoring these enforcement actions.  Change of Legal Environment  1.       Areas:             New law or regulation             Update:             State level: No developments             Local level (Beijing & Shanghai): No developments             Communist Party Rules:… Continue Reading

Monthly China Anticorruption Update Report-August 2012

Posted in Uncategorized

The most recent FCPA and anticorruption enforcement developments involving the People’s Republic of China (PRC) are summarized below. Thanks as always to Squire Sanders Shanghai Office for monitoring these enforcement actions. Change of Legal Environment 1.     Areas: New law or regulation          Update: State level:  No developments Local level (Beijing &… Continue Reading

The Importance of Bribery and Corruption Due Diligence in Corporate Transactions

Posted in Uncategorized

To protect themselves from breaking  the UK Bribery Act and Proceeds of Crime legislation, those involved with corporate transactions (including mergers, acquisitions or investments) need to ensure that transactions do not involve risks of bribery and corruption. The UK’s Serious Fraud Office (SFO), in January 2012, said: “Shareholders and investors in companies are obliged to… Continue Reading

Orthofix International Resolves FCPA Investigation

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Orthofix International N.V. (“Orthofix”) entered into a consent to final judgment with the SEC and a deferred prosecution agreement with the DOJ to resolve FCPA violations by its Mexican subsidiary. Although the DOJ enforcement action involved a criminal information which remains sealed until a plea is entered in open court, the deferred prosecution agreement indicates… Continue Reading

Deferred prosecution agreements in the UK- Consultation now open

Posted in Uncategorized

Back in May, we reported that the new Director of the SFO had offered support to the US-style deferred prosecution agreements (“DPAs”). DPAs aim to make out-of-court settlements easier by allowing defendant companies to avoid criminal prosecution instead agreeing a series of conditions. These conditions usually including paying a civil penalty, handing back the profits… Continue Reading

Another Haitian Government Official Sentenced in Haiti Teleco Corruption Scheme

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As discussed in a previous blog post, the DOJ has been prosecuting multiple individuals in the Haiti Teleco corruption scheme.  On May 21, 2012 Jean Rene Duperval was sentenced to nine years in prison for his role in the scheme to launder bribes paid to him by two Miami-based telecommunications companies.  Duperval was also ordered… Continue Reading

German Prosecutors investigate accusations against German energy giant EnBW

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Mannheim Public Prosecutor’s office announced they are currently reviewing whether official preliminary proceedings against Germany based company Energie Baden-Wuerttemberg (EnBW) will be initiated. Possible charges comprise embezzlement, tax evasion and bribery. Mannheim prosecutors, specialized in white-collar crime, took over the case from Karlsruhe Public Prosecutor’s office where the proceedings were investigated since September 2011. EnBW,… Continue Reading

U.S. Chamber of Commerce Seeks Guidance Concerning the FCPA

Posted in Uncategorized

On February 21, 2012 The U.S. Chamber of Commerce Institute for Legal Reform (ILR) sent a letter to the DOJ requesting guidance on “several issues and questions of significant concern to businesses seeking in good faith to comply with the FCPA.”  The ILR raised the following issues: “Instrumentalities”: The ILR sought clarification on what types… Continue Reading

John Joseph O’Shea Acquitted of All Substantive FCPA Counts

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Conduct Following the close of the prosecution’s case on a trial for charges arising under the Foreign Corrupt Practices Act (“FCPA”), John Joseph O’Shea (“O’Shea”) was acquitted of all substantive FCPA counts, with the court (Southern District of Texas) finding that O’Shea’s conduct could be reasonably explained by lawful motives.  O’Shea, a former general manager… Continue Reading

Allianz SE to settle SEC charges linked to bribes in Indonesia

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Europe’s largest insurance company, Germany-based Allianz SE, apparently is about to limit damages sustained by United States Securities and Exchange Commission (SEC) investigations. The insurer had been under US investigation for its possible involvement in two major bribe cases. The first case began after allegations gave rise to suspicion that Allianz employees were involved in… Continue Reading

German Banker charged with receipt of bribe payments after sale of Formula One – Bernie Ecclestone’s involvement investigated

Posted in Uncategorized

On Monday, July 18th, Munich prosecutors indicted Gerhard Gribkowsky, former board member of the Bavarian Regional Bank (Bayerische Landesbank, also known as BayernLB), for tax evasion, breach of trust and receipt of corrupt payments. The accusations include failing to pay taxes in Germany trying to conceal payments of bribery money. The defendant has been in… Continue Reading

ANTI-BRIBERY AND CORRUPTION: A SPECIAL REPORT

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Thomson Reuters Accelus has recently published a special report (PDF/1.43MB/28 pages) on anti-bribery and corruption and the increased burden on senior management. It is particularly pertinent in light of the Bribery Act 2010 (“Act”) coming into force tomorrow. Among other things, it contains some useful discussion on: sector specific issues and guidance; whether foreign issuers with a London… Continue Reading

SEC Adopts Final Rules Providing for Cash Award Payments to Whistleblowers

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On May 25, 2011, the Securities and Exchange Commission (SEC) adopted final rules implementing the controversial “whistleblower” provisions of the Dodd-Frank Act, which provide for the payment of monetary awards to individuals who report possible violations of the federal securities laws to the SEC.  Under Section 922 of the Dodd-Frank Act, if a whistleblower provides… Continue Reading