Tuesday, October 26, 2021

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WPP Enforcement Action by SEC

Tom Fox analyzes the SEC’s recent FCPA enforcement action against WPP plc, the world’s largest advertising group, for bribes to Indian government officials and “illicit schemes” in China, Brazil, and Peru. WPP agreed to pay more than $11 million in disgorgement and interest, and a penalty of $8 million. “All I can say is that […]
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Emerging Corporate Liability for Bribery in Europe, Latin America

Richard L. Cassin writes approvingly of a shift in how bribery and ESG issues are being held accountable in Europe. “It seems obvious now that corporations should be held responsible for their overseas graft,” comments Cassin. “Remarkably, though, many European and Latin American countries resisted the concept.” France introduced corporate criminal liability for overseas bribery […]
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Global Advertising Group WPP Settles Multiple Local Bribery Charges with SEC for $19.2 Million

The SEC has reached a $19.2 million settlement with WPP plc – the world’s largest advertising group – for activities in India, China, Brazil, and Peru, which allegedly violated the anti-bribery, books and records, and internal accounting controls provisions of the FCPA. The company acquired agencies in a number of high-risk markets, but failed to […]
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FCA Proposal Is Unfair And Would Hinder Economic Growth

As American industry moves toward building back better in the face of a continuing pandemic, Sens. Chuck Grassley, R-Iowa, and Patrick Leahy, D-Vt., have...

FCPA Prosecutor Foreshadows Increased Use of New Foreign Bank Subpoena Tool

Nine months ago, Congress gave the Departments of Justice and Treasury substantial new power to subpoena foreign-located bank records in any investigation under federal criminal law, as part of the Anti-Money Laundering Act of 2020 under the 2021 National Defense Authorization Act. It permits DOJ and Treasury to subpoena foreign-located bank records if the bank […]
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WPP Settles with SEC Over Allegations in Several Countries

The world’s largest advertising group, WPP plc, has agreed to pay the SEC $8 million in penalties and $11.2 million in disgorgement to resolve FCPA anti-bribery, books and records, and internal accounting controls offenses in India, China, Brazil, Peru, and elsewhere. In India, bribes totaling over a million dollars went to officials of the Departments […]
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The Myth of Corporate Resources and Efficiency

When I was a federal prosecutor and investigating corporations for misconduct, I imagined a well-oiled machine with vast resources, capable of overwhelming government prosecutors and law enforcement agents with lawyers, resources and influence. To the contrary, corporate resources are often spread thin. Resources are tight. Corporate operations are run without waste. This does not mean […]
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Bringing Order to the Chaos – Navigating the Steps of a FCPA Investigation

In this “Fraud Eats Strategy” series, Scott Moritz of FTI Consulting discusses with Kim Parker of WilmerHale and Mike Archibald of FTI how to bring order to the chaos of the early days of an FCPA investigation, and avoid mortgaging the company’s future in the process. Source – Compliance Podcast Network: Navigating the Steps of […]
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Top 10 International Anti-Corruption Developments for August 2021

In its latest monthly review, Morrison Foerster summarizes some of the most important international anti-corruption law and case developments from the past month. This...

Straight Talk on FCPA Training for Tech and Fintech Companies

In a commentary on Legaltech News, Miller & Chevalier’s Jeffrey A. Lehtman and Leah Moushey provide practical guidance on the most frequently asked questions by legal and compliance personnel at late-stage private and newly public tech and fintech companies around anti-corruption compliance training. They discuss who needs training, when training should begin, and what elements […]
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