Search

Editors

Richard L. Cassin Publisher and Editor

Andy Spalding Senior Editor

Jessica Tillipman Senior Editor

 

Elizabeth K. Spahn 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

Connect
FCPA Blog Daily News

Entries in Foreign Official (151)

Tuesday
Nov292016

Paul T. Oki: Knowing who to run from is half the compliance battle

Doing business in countries perceived to be high risk for corruption and FCPA compliance issues (and unhappily my country Nigeria sits squarely within that category) requires a clear picture of who your local partners are, and whether associating with them represents any sort of risk to you from a compliance perspective.

Click to read more ...

Monday
Nov072016

Scott Moritz: A plan to integrate the compliance program after an acquisition

As mentioned in my post last week, one way the DOJ determines if a company has performed the required anti-corruption due diligence when acquiring an entity is looking at whether the new entity was promptly incorporated into the acquiring company’s internal controls, including its compliance program.

Click to read more ...

Thursday
Jun022016

DOJ names permanent chief of FCPA Unit

The DOJ announced that Daniel Kahn became Chief of the FCPA Unit, effective June 1.

Click to read more ...

Tuesday
May312016

Hiring foreign officials: How do you justify it?

One of the threshold questions for a company considering the engagement of a government official is whether the engagement is needed for legitimate purposes. If the company cannot articulate an adequate and appropriate business justification, there is a risk that the engagement may be sought or undertaken for a corrupt purpose.

Click to read more ...

Monday
May232016

Practice Alert: Engaging foreign officials as consultants and speakers

Companies operating in emerging markets sometimes retain qualified government officials to provide services such as consulting or speaking. In some circumstances, particularly in developing markets, these services are necessary and can serve a company’s legitimate business needs.

Click to read more ...

Wednesday
May042016

Why some doctors at China state-owned hospitals may not be ‘foreign officials’

A recent scandal at a major Chinese public hospital revealed that many of the public hospitals across the country outsource their medical services to private companies and employ doctors as independent contractors.  That could raise doubts about some public hospital doctors in China being "foreign officials" under the FCPA.

Click to read more ...

Tuesday
Apr122016

Bill Steinman: Let's talk about per diems, without the shouting

Per diems. We in the FCPA bar love to hate them, and with good reason. Who likes the idea of giving cash to foreign officials? If there’s anything that should rankle the anti-corruption specialist, this is it. 

Click to read more ...

Wednesday
Mar092016

Compliance alert: India Supremes say private bankers are ‘public servants’

The Indian Supreme Court has expanded the definition of public servant in a decision that has implications for not only the banking system but potentially the country’s broader struggle against corruption.

Click to read more ...

Wednesday
Jan202016

Sundar Narayanan: Is your next compliance problem at a toll booth in Delhi?

Delhi recently started enforcing new traffic regulations to reduce pollution levels. In October 2015, the city -- properly the National Capital Territory, where 10 million people live -- imposed a Green Tax on vehicles. 

Click to read more ...

Monday
Aug312015

Russian nuke official, two others plead guilty in FCPA-related case

A Russian official living in Maryland pleaded guilty Monday to conspiracy to commit money laundering for taking over $2 million in bribes in exchange for transport contracts with the Russian state-owned nuclear energy corporation.

Click to read more ...

Monday
Aug242015

How to hire a princeling: Six rules anyone can follow

Last week BNY Mellon agreed to pay the SEC $14.8 million to settle charges that it violated the Foreign Corrupt Practices Act by awarding student internships to kids of officials connected with a sovereign wealth fund in the Middle East.

Click to read more ...

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:

Click to read more ...