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FCPA Blog Daily News

Entries in Declinations (73)

Tuesday
Oct012013

Enforcement Report for Q3 ‘13

DOJ and SEC enforcement of the FCPA slowed a bit during the summer months. But after a blockbuster Q2, the third quarter still saw four guilty pleas, one more than the prior quarter, and three declinations, up from two in the previous three months.

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Thursday
Apr182013

Enforcement is back (if it ever left)

Acting Assistant Attorney General Mythili Raman of the Justice Department’s Criminal Division Did someone say FCPA enforcement had slowed down? Look again.

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Tuesday
Apr092013

Has enforcement really slowed down? Maybe not

Following publication last week of the Corporate Investigations List, a long-time FCPA Blog reader sent the following comment:

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Monday
Apr012013

Enforcement Report for Q1 '13

It was a quiet start to the year, with just one stealth enforcement action by the SEC that didn't mentioned the FCPA by name, and none by the DOJ.

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Thursday
Mar282013

Declination for DynCorp

The parent company of Virginia-based DynCorp International Inc. said Wednesday the DOJ won't bring an enforcement action following an investigation into payments by two subcontractors to speed up the issuance of visas and permits.

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Thursday
Feb282013

Double declination for Zimmer

Following a five-year investigation into the overseas marketing and sales practices of medical device makers, the DOJ and SEC won't bring any FCPA enforcement against one of the targeted companies, Zimmer Holdings Inc.

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Thursday
Feb212013

Nabors wins declination

Oil services firm Nabors Industries Ltd. said Wednesday the DOJ won't bring an FCPA enforcement action after an investigation first launched more than five years ago.

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Wednesday
Feb202013

Declination for 3M

In its annual report filed with the SEC on February 14, Minnesota-based 3M Company said the DOJ and SEC won't bring an FCPA enforcement action following an internal investigation into allegations of bid rigging and bribery by a subsidiary in Turkey.

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Thursday
Jan242013

Final count for 2012 declinations

In the prior post, I explained why a broad definition of 'declinations' is needed to overcome a lack transparency by the DOJ and SEC when tracking agency decisions conclude FCPA investigations without pursuing enforcement actions.

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Tuesday
Jan222013

Revisiting the Definition of 'Declinations'

In a recent post, the FCPA Professor questioned the broad application of the label “declination” to any instance of FCPA scrutiny that does not result in an FCPA enforcement action.

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Friday
Dec282012

The top five FCPA stories of 2012

1. Allegations against Wal-Mart -- Just when the debate about FCPA reform was heating up, the New York Times reported that Wal-Mart may have paid $24 million in bribes to Mexican officials to grow the business. The story showed why the FCPA is important. And it derailed the Chamber of Commerce's campaign to narrow the law and restrict the DOJ's enforcement of it.

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Thursday
Dec272012

2012: The year in declinations

FCPA declinations -- decisions not to prosecute a company after an investigation -- are hard to track.

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