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FCPA Blog Daily News

Entries in Kara Brockmeyer (15)


SEC names new boss of FCPA unit

The Securities and Exchange Commission said Thursday that Charles Cain is the new Chief of the Enforcement Division's Foreign Corrupt Practices Act Unit.

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Brockmeyer joins Debevoise in DC

Debevoise & Plimpton LLP said Monday that Kara Novaco Brockmeyer, former chief of the SEC's Foreign Corrupt Practices Act Unit, is joining the firm’s Washington, DC office.

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Bill Coffin: Celebrate 40 years of the FCPA at Compliance Week 2017

When it was signed into law in 1977, the Foreign Corrupt Practices Act was very much an American approach to a global problem: how corruption in general and bribery in particular was skewing international business.

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FCPA chief leaving SEC

The Securities and Exchange Commission said Tuesday that Kara Novaco Brockmeyer, Chief of the Enforcement Division’s Foreign Corrupt Practices Act Unit, is planning to leave the agency later this month.

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Alexandra Wrage: Compliance and Enforcement Trends from the 2017 TRACE Forum

Last week, TRACE held its 13th Forum at the St. Regis Hotel in Washington, D.C. Over 100 member companies contributed to a lively and extended exchange of best practices across the two-day event.

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Jordan A. Thomas: Welcome to the whistleblower revolution

Secrets. We all have them. It’s human nature to keep them. But given recent enforcement actions initiated by whistleblowers, one thing is clear: a good secret has a high price tag.

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Field trip: Conducting preliminary market visits

In the e-book we wrote as a guide to navigating corruption challenges in emerging markets, we talk in one chapter about the particular risks companies face when they enter new markets.

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Hitachi pays $19 million in FCPA settlement for South Africa bribes

The Securities and Exchange Commission Monday charged Tokyo-based conglomerate Hitachi, Ltd. with violating the Foreign Corrupt Practices Act when it inaccurately recorded improper payments to South Africa’s ruling political party in connection with contracts to build two multi-billion dollar power plants.

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BNY Mellon pays $15 million in FCPA settlement for internship hiring practices

The Securities and Exchange Commission Tuesday said BNY Mellon agreed to pay $14.8 million to settle charges that it violated the Foreign Corrupt Practices Act by providing valuable student internships to family members of foreign government officials affiliated with a Middle Eastern sovereign wealth fund.

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A closer look at the revisions to the FCPA Guide

Several articles over the past few days have reported that the DOJ and SEC are quietly revising A Resource Guide to the FCPA, the joint guidance the agencies issued on November 14, 2012, including one article that suggested these revisions occurred as recently as June of this year (see also here and here). In fact, the more substantive of the changes flagged by these articles were made on or before December 9, 2012, less than 30 days after the release of the Guide, in response to feedback practitioners provided to the agencies.

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Are FCPA books and records and internal controls defenses becoming obsolete?

Many of us scratched our head in 2010 when the Oracle FCPA enforcement action came out. We didn't understand how a company could be prosecuted, even civilly by the SEC for internal controls or book and records violations, without evidence that bribes had been paid. But after the past few months, I think Oracle was a precursor to a strict liability standard that's coming to FCPA enforcement.

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Are Administrative Proceedings the New Civil Complaints?

Click to enlargeAt ACI's annual FCPA Conference last November, SEC FCPA Unit Chief Kara N. Brockmeyer disclosed that the SEC expects to rely more frequently on administrative proceedings (as opposed to more traditional civil court actions) to resolve FCPA-related enforcement matters.

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