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Bribery Act Investigations at Rolls Royce

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

Monthly China Anticorruption Update Report— November 2012

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. 1. New law or regulationState level:(1) Criminal Procedural Rules of the People’s Procuratorate On November 20, the Supreme People’s Procuratorate (“SPP”), the highest procuratorial … Continue Reading

Judge Hands Down Sentences on Former CCI CEO, Sales Director

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

Monthly China Anticorruption Update Report-September 2012

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

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

Monthly China Anticorruption Update Report– July 2012

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. New Law or Regulations State level: (1) Regulations on the Management of Governmental Affairs On July 9, the Chinese Sate Council promulgated the new … Continue Reading

Nordam Group Settles China FCPA Violations

On July 17, 2012, Nordam Group, Inc. (“Nordam”) an aircraft maintenance, repair and overhaul (“MRO”) service provider based in Tulsa, Oklahoma, entered into a three-year non-prosecution agreement (NPA) with the DOJ to resolve violations of the FCPA’s anti-bribery provisions. Conduct According to the NPA, from 1999 until 2008, Nordam, its subsidiaries and affiliates paid bribes … Continue Reading

Monthly China Anticorruption Update Report– June 2012

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 China Enforcement Actions (1) On June 5, Wu Xiaoli (“Wu”), former general manager of the Shanghai Gongxin Project Construction Supervision Center Ltd, a state-owned … Continue Reading

Monthly China Anticorruption Update Report– May 2012

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. China Enforcement Actions (1) On April 26, 2012, Jiao Baohua (“Jiao”), municipal party secretary of Yining City, Yili Kazak Autonomous County, Urumqi Municipality was … Continue Reading

Former CCI Executive Cops Plea

Paul Cosgrove, the former head of worldwide sales at California-based valve manufacturer Control Components Inc. (CCI) pleaded guilty yesterday to violating the Foreign Corrupt Practices Act (FCPA).  Cosgrove is the fourth of six company executives to plead guilty to violating or conspiring to violate the FCPA. Cosgrove was previously scheduled to stand trial on June … Continue Reading

Monthly China Anticorruption Update Report– April 2012

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 and reporting on these enforcement actions. China Enforcement Actions (1) On March 31, 2012, Li Ping, former Party chief of Futian District committee, wassentenced to six-and-a-half years … Continue Reading

Monthly China Anti-Bribery Update Report– March 2012

As part of our continued efforts to monitor the antibribery enforcement environment in the People’s Republic of China (PRC), our colleagues in Squire Sanders’ Shanghai office have graciously agreed to provide monthly updates of relevant developments in the PRC’s antibribery laws, regulations and government enforcement actions. The most recent developments are summarized below. Enforcement Actions … Continue Reading

Monthly China Anti-Bribery Update Report– February 2012

The following monthly update on developments in the People’s Republic of China’s (“PRC”) antibribery laws, regulations and government enforcement actions is brought to you with the assistance of our colleagues in Squire Sanders’ Shanghai Office. Enforcement Actions (1)  On February 8, 2012, Chen Meng (“Chen”), former chief deputy official of Putuo District, Shanghai, went on … Continue Reading

Monthly China Anti-Bribery Update Report– December 2011 – January 31, 2012

As part of our continued efforts to monitor the antibribery enforcement environment in the People’s Republic of China (PRC), our colleagues in Squire Sanders’ Shanghai office have graciously agreed to provide monthly updates of relevant developments in the PRC’s antibribery laws, regulations and government enforcement actions. The most recent developments are summarized below. Enforcement Actions … Continue Reading

Bribery Charges Dismissed Against Former Schnitzer Steel Executive

On October 14, 2011, the DOJ dismissed bribery charges against Si Chan Wooh, the former Executive Vice President and head of Schnitzer Steel Industries, Inc.’s (“Schnitzer Steel”) Tacoma, Washington based subsidiary SSI International which oversaw Schnitzer Steel’s South Korean subsidiary, SSI Korea. Back in 2007, Wooh previously entered into a cooperation agreement with the DOJ … Continue Reading

SEC Issues FCPA Cease and Desist Order as to Watts Water Technologies, General Manager of Chinese Subsidiary

The Securities and Exchange Commission (“SEC”) has issued an administrative cease and desist order as to Watts Water Technologies, Inc. (“Watts”), a water valve designer and retailer, and Leesen Chang (“Chang”), former general manager of Watts Valve Changsha Co., a wholly-owned Chinese subsidiary of Watts. Conduct Between 2006 and 2009, Chang, on behalf of Watts’s … Continue Reading

Getting The Deal Through – Anti-Corruption Regulation 2011

Members of the Squire Sanders China team have written the China chapter to the fifth edition of Getting the Deal Through – Anti-Corruption Regulation 2011, which provides international analysis in key areas of law and policy for corporate counsel, cross-border legal practitioners and business people. Following the format adopted throughout the series, our China team has provided responses … Continue Reading

China’s Amendment to the Criminal Law to Outlaw Bribery of Foreign Officials Becomes Effective

An amendment of the PRC Criminal Law which criminalizes bribery of foreign government officials and “international public organizations” to secure illegitimate business benefits went into effect on May 1, 2011. The PRC did not have any law addressing cross-border bribery before and this law will be the first law to condemn bribery of foreign officials. This … Continue Reading

IBM and the SEC Settle Up

IBM resolved an enforcement action brought by the SEC, which alleged the company violated the FCPA’s books and records and internal controls provisions.  SEC alleged IBM subsidiaries and an IBM join-venture made illicit payments and provided gifts, travel and entertainment to Chinese and South Korean government officials for improper purposes.  IBM did not admit nor … Continue Reading

Thinking about China’s Amended Criminal Law: More Questions than Answers

On February 25, 2011, China adopted Amendment No. 8 of the PRC Criminal Law, which criminalizes bribery of foreign government officials and of international public organizations in order to secure illegitimate business benefits. Previously, the focus of PRC antibribery laws and regulations had been on bribery – both involving officials and purely commercial parties — in a … Continue Reading

Social Audits with Chinese Characteristics: PRC Higher Courts’ Online Complaint Tool

At the end of last year, successful use of ‘social audits’ in India to enable citizens to ensure  public officials are applying public funds properly received media attention. By turning citizens into watchdogs at the local level, thousands of corrupt officials have been caught and information sharing is a key part of the audit process: “The results … Continue Reading

Foshan Meijiao Trading’s attempted bribery of PEMEX execs: Update from China

Thanks to SSD Network colleague Humberto Morales for updating us on the view from inside Mexico of the arrest of 2 Chinese nationals for attempted bribery of 2 PEMEX executives. Humberto is a former GC for General Electric in Mexico and will be a regular contributor o The Anticorruption Blog on Mexico-related matters. His post made me wonder … Continue Reading
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