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FCPA Blog Daily News

Entries in Declinations (59)

Friday
Aug112017

Karen Gray: How consistency can make or break a compliance program

Business philosopher Jim Rohn said: “Success is neither magical nor mysterious. Success is the natural consequence of consistently applying basic fundamentals.”

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Tuesday
Aug082017

MTS Systems says FCPA probes have ended

Minnesota-based MTS Systems Corporation said Monday that FCPA investigations related to China and Korea are complete and the DOJ and SEC aren't bringing enforcement actions.

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Wednesday
Jul262017

DOJ declination for Newmont Mining

Newmont Mining Corporation said in an SEC filing Tuesday that the DOJ is closing its FCPA investigation of the company.

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Wednesday
Apr262017

Newmont Mining discloses SEC declination

One of the world's biggest gold miners said in a securities filing this week that the SEC won't recommend an FCPA enforcement action against the company.

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Monday
Apr032017

FCPA enforcement report for Q1 2017

During the first calendar quarter, there were six corporate FCPA enforcement actions and one individual resolution.

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Friday
Mar102017

DOJ will keep Pilot Program after April expiry during evaluation

A DOJ official said Friday the Pilot Program won't expire on April 5 but will continue while the agency evaluates how the program has worked and whether it should be extended or changed.

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Thursday
Mar022017

Crawford & Company reports SEC declination

Claims management company Crawford & Company said in its annual report that the Securities and Exchange Commission has finished its FCPA investigation and won't bring an enforcement action against the company.

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Monday
Feb202017

Question: Are there ever FCPA prosecutions for small bribes?

A reader asked if there have been any FCPA cases involving small bribes -- say under $1 million. The answer is: Yes, lots of them.

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Tuesday
Jan032017

The 2016 FCPA Enforcement Index

Last year 27 companies paid about $2.48 billion to resolve FCPA cases. It was the biggest enforcement year in FCPA history. Both the number of enforcement actions and the overall amounts paid to resolve them were records.

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Monday
Dec192016

Rebecca Gantt: Looking for clues about the future of the Pilot Program

Last April, the DOJ's Criminal Division launched the one-year Pilot Program. The remaining four months of the Pilot Program promise to provide valuable information on several fronts.

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Wednesday
Nov302016

Daniel Patrick Wendt: So how does the DOJ calculate disgorgement?

In the prior post I talked about how, after nearly 40 years of FCPA history, the DOJ first used disgorgement as a remedy, including it this year in two declinations under the Pilot Program.

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Monday
Nov282016

Daniel Patrick Wendt: Are those DOJ disgorgements really disgorgement?

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. 

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