This year the DOJ required disgorgement of ill-gotten gains as a predicate for preferential treatment under the new FCPA enforcement Pilot Program, regardless of whether the participating company was publicly or privately owned.
Entries in Akamai (8)
The Justice Department released letters Thursday under the DOJ's Pilot Program to two Texas companies that won't be prosecuted for violating the FCPA but will each have to disgorge all profits they made from the bribery.
During the second calendar quarter, there were four corporate FCPA enforcement actions and eight individual resolutions (seven related to Direct Access Partners). There were also three guilty pleas by individuals.
As reported by the FCPA Blog Tuesday, the SEC and DOJ entered into parallel resolutions with Analogic Corporation and Analogic's wholly-owned Danish subsidiary BK Medical ApS in connection with violations of the books and records and accounting controls provisions of the FCPA.
The Securities and Exchange Commission Tuesday announced non-prosecution agreements (NPAs) with two unrelated companies for bribes foreign subsidiaries paid to Chinese officials.