Search

Editors

Harry Cassin Publisher and Editor

Andy Spalding Senior Editor

Jessica Tillipman Senior Editor

Richard L. Cassin Editor at Large

Elizabeth K. Spahn Editor Emeritus 

Cody Worthington Contributing Editor

Julie DiMauro Contributing Editor

Thomas Fox Contributing Editor

Marc Alain Bohn Contributing Editor

Bill Waite Contributing Editor

Shruti J. Shah Contributing Editor

Russell A. Stamets Contributing Editor

Richard Bistrong Contributing Editor 

Eric Carlson Contributing Editor

Bill Steinman Contributing Editor

Aarti Maharaj Contributing Editor


FCPA Blog Daily News

« New DOJ opinion on promotional expenses by non-profit adoption agencies | Main | In Pakistan, an old graft case stirs new fears »
Friday
Oct262012

Embraer's latest FCPA disclosure (October 2012)

From the FCPA Blog members area, here's Embraer S.A.'s FCPA disclosure in its SEC filing on October 24:

We, through our outside counsel hired to respond to the SEC-issued subpoena and associated inquiries into the possibility of non-compliance with the U.S. Foreign Corrupt Practices Act, or FCPA, continue to cooperate fully with the SEC and U.S. Department of Justice, or DOJ, in their investigation of such matters. As part of the cooperation, our outside counsel has reported to the SEC and DOJ with respect to its internal investigation, which is continuing, and has provided information requested by, and responded to questions from, the SEC and DOJ. The SEC and DOJ investigations continue, and our management, with the support of our outside counsel, continues to believe that it is not possible to estimate the duration, scope or results of the investigations. In the event that the SEC and/or DOJ investigations result in enforcement action, we may be required to pay substantial fines and/or to incur other sanctions, as provided in the FCPA. Our management, based upon the opinion of our outside counsel, continues to believe that there is no basis for estimating reserves or quantifying any possible contingency.

For instant access to every FCPA disclosure filed with the SEC, join the FCPA Blog members area today.

Reader Comments

There are no comments for this journal entry. To create a new comment, use the form below.

PostPost a New Comment

Enter your information below to add a new comment.

My response is on my own website »
Author Email (optional):
Author URL (optional):
Post:
 
All HTML will be escaped. Hyperlinks will be created for URLs automatically.