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FCPA Blog Daily News

Entries in Declinations (73)

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.

Click to read more ...

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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Wednesday
Nov232016

JPMorgan lands on the FCPA Top Ten Disgorgement List

Last week's $264 million enforcement action against JPMorgan Chase included disgorgement to the SEC of $130.5 million -- the seventh biggest FCPA disgorgement of all time.

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Saturday
Oct292016

Fox and Rosen: What went down in New York City

In their latest podcast, Tom Fox and Jay Rosen talk about Wednesday's FCPA Blog NYC Conference.

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Wednesday
Oct192016

Lennox International discloses alleged $425 (no zeroes) Russia bribe

Texas-based Lennox International Inc. said in a securities filing Monday that it self reported to the SEC and DOJ an alleged payment of $475 to a Russian customs broker or official.

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Friday
Sep302016

DOJ breaks new ground with two ‘declinations with disgorgement’

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.

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Friday
Sep092016

Cisco investigation ends with DOJ, SEC declinations

Networking giant Cisco Systems Inc. said in its annual report Thursday that following an investigation into operations in Russia and some CIS countries, the DOJ and SEC won't bring FCPA enforcement actions.

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Friday
Jul012016

FCPA enforcement report for Q2 2016

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.

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Wednesday
Jun082016

Here's what a Pilot Program declination letter looks like

After Nortek and Akamai resolved FCPA enforcement actions with the SEC Tuesday with non-prosecution agreements requiring cooperation and disgorgement, both companies released declination letters issued under the DOJ's new Pilot Program.

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Tuesday
Jun072016

Akamai, Nortek settle China bribe cases with SEC non-prosecution agreements

The Securities and Exchange Commission Tuesday announced non-prosecution agreements (NPAs) with two unrelated companies for bribes foreign subsidiaries paid to Chinese officials.

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Monday
May022016

DOJ declination for Key Energy, SEC settlement reached ‘in principle’

Key Energy Services Inc. said Thursday the Justice Department informed the company that it has closed its FCPA investigation and won't bring an enforcement action.

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Tuesday
Apr052016

DOJ launches FCPA self-reporting pilot program with new guidance

Assistant Attorney General Leslie R. CaldwellAssistant Attorney General Leslie Caldwell announced a one-year pilot program Tuesday intended to encourage companies to self report FCPA offenses and cooperate with the Justice Department.

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