Entries in Gift Giving (34)
MTS Systems Corporation said it has investigated possible violations of the FCPA and in January 'presented the results of its investigation and its corrective actions to representatives of the Department of Justice and the SEC.'
Florida-based Harris Corporation said this week it has received a 'formal order of investigation' from the SEC relating to the operations of its Carefx subsidiary in China.
Minnesota-based MTS Systems Corporation said last week that after an investigation of gift-giving, travel, and accommodation practices in its Asia operations, it '[removed] certain persons formerly employed in its Korea office.'
Under the general topic of graft, school corruption is a well-recognized sub-genre.
Last month, the Criminal Division of the U.S. Department of Justice and the Securities and Exchange Commission published their long-awaited Resource Guide to the U.S. Foreign Corrupt Practices Act.
Both the guidance and recent remarks by officials make clear that, although the FCPA has no value threshold, the government is not interested in bringing cases over de minimis payments to foreign officials.
Last week, the DOJ and SEC issued their long-anticipated Resource Guide regarding the agencies’ FCPA enforcement. Over a year in the drafting, the 120-page Guide addresses, among other things, (1) the definition of a foreign official, (2) gifts and entertainment, and (3) the “hallmarks” of an effective corporate compliance program.
Here's what Robert Khuzami said Wednesday at a news briefing about the FCPA guidance released by the DOJ and SEC. Khuzami is head of the SEC's enforcement division.