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Entries in Foreign Official (140)

Monday
Jun152015

Brazil's Electrobras hires Hogan Lovells for bribery investigation

Dear FCPA Blog,

You may have seen this announcement in an SEC filing on June 10 by the Brazilian-owned electric company Centrais Eletricas Brasileiras SA –Electrobras:

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Friday
Mar062015

A free press exposes graft and restrains greed

The FCPA Blog reminds itself often that freedom of the press and free speech are the most powerful weapons against corruption. As Louis Brandeis said, sunlight is the best disinfectant.

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Tuesday
Mar032015

The business community can reduce corruption risk by improving regulatory quality

Contacts with a government in the course of conducting every day business raise the risk of providing something of value to a foreign official. This risk can be minimized via appropriate controls and efforts on the part of industry groups, through collective action, to improve regulatory quality.

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Thursday
Feb052015

CSR shouldn't stand for Corrupting Society Responsibly

One area of potential FCPA risk that doesn’t get much attention, or as much as it should, is how companies meet their Corporate Social Responsibility (CSR) objectives on mega projects (oil, gas, mining, infrastructure, etc.). Without the proper systems in place, and properly trained staff, project directors and CSR managers may inadvertently violate the FCPA by providing something of value to a foreign official to alleviate delays caused by conflict in the community.

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Wednesday
Jan282015

SEC recommends FCPA charges against BNY Mellon for sovereign wealth fund practices

Bank of New York Mellon Corp. said the SEC has recommended an enforcement action for possible FCPA violations related to the bank's dealings with sovereign wealth funds.

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Tuesday
Jan272015

International Franchising and the FCPA (Part Two): A Flock of Foreign Officials 

This post continues from Part One: Vicarious Liability. There are several types of foreign officials that interact with a franchise’s broad array of potential agents abroad, which generates anti-corruption risks.

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Monday
Jan122015

Not every princeling job is a ‘thing of value’

In our era of talk shows, sound bytes, and political polarization, we can easily lose sight of a simple truth: the free exchange of ideas can be beautiful. The beauty lies in its potential to evoke ever more considered and disciplined views from the participants. In rare cases, it can even draw both sides toward a carefully formulated resolution that is satisfying to both.

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Monday
Jan122015

Secret recordings by PetroTiger general counsel admitted as evidence against former CEO

A federal judge in New Jersey ruled last week that prosecutors can use secret video recordings in the trial of the former PetroTiger CEO that the FBI made with a camera attached to the executive's lawyer.

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Friday
Dec052014

Why FCPA history matters: ‘Congress was distraught’ 

President Jimmy Carter addresses Congres in 1977Joseph Sigelman, the former co-CEO of PetroTiger Ltd., is the latest defendant to argue that employees of state-owned enterprises aren't "foreign officials" under the FCPA. He was charged in May with bribing an official at Ecopetrol SA, Colombia’s state-controlled oil company, and defrauding PetroTiger by taking kickbacks.

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Monday
Nov242014

IKEA’s charitable giving in Russia and the FCPA (Part Six)

This is the final post in my series analyzing IKEA’s charitable contributions in Russia in the 1990s and early 2000s. I haven’t presumed IKEA was subject to the FCPA when the events happened or that any FCPA violations might have occurred. Instead, I’ve looked at IKEA’s Russia experience to learn more about charitable giving under the FCPA and how to manage giving programs.

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