In remarks at NYU’s Program on Corporate Compliance and Enforcement, Steven Peikin, the new Co-Director of the SEC’s Enforcement Division, voiced a question that has been on the minds of many anticorruption practitioners and compliance professionals: Will the SEC continue to be committed to robust FCPA enforcement?” “My answer to that question is simple,” Peikin … Continue Reading
Aon Corp., an Illinois-based world leader in risk management, insurance, and reinsurance brokerage services, has entered into a Non-Prosecution Agreement (“NPA”) with the Department of Justice (“DOJ”) and has settled a civil action brought by the Securities and Exchange Commission (“SEC”) stemming from alleged violations of the anti-bribery, books and records, and internal controls provisions … Continue Reading
Ball, an Indiana corporation based in Colorado that manufactures metal packaging for household goods, food and beverages, and provides aerospace and technological services, resolved an enforcement action in which the SEC alleged it violated the FCPA’s books and records and internal controls provisions. Conduct The SEC alleged Ball, through a subsidiary, Formametal, S.A., acquired in … Continue Reading
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
Not too long ago I was clicking through the greatly improved DOJ FCPA webpage when I stumbled onto an enforcement action that had flown under the anticorruption/compliance blogosphere’s radar. Yes, Manuel Salvoch had escaped the dreaded DOJ press release, but not the Fraud Section’s posting of documents for the world to see. It was only … Continue Reading
On Friday, March 11, Jeffrey Tesler, who had challenged extradition from the UK to the US, relented in his fight and pleaded guilty to one count of conspiracy to violate the FCPA and one substantive violation of an FCPA antibribery provision. In 2009, the DOJ initially charged Tesler in an 11 count indictment consisting of … Continue Reading
