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 […]
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 […]
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 […]
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...
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 […]
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 […]
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 […]
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 […]
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...
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 […]