Entries in Pilot Progam (14)
President Elect Trump’s pick to lead the SEC is Jay Clayton. He wrote in a 2011 NYC Bar Association paper about the FCPA. The paper addressed the “lasting harm to the competitiveness of U.S. regulated companies” due to the “current anti-bribery regime.”
This year the DOJ required disgorgement of ill-gotten gains as a predicate for preferential treatment under the new FCPA enforcement Pilot Program, regardless of whether the participating company was publicly or privately owned.
Last week's $264 million enforcement action against JPMorgan Chase included disgorgement to the SEC of $130.5 million -- the seventh biggest FCPA disgorgement of all time.
DOJ criminal division chief Leslie Caldwell used a wide-ranging talk Thursday at George Washington University Law School to defend the six-month old Pilot Program and to describe the Justice Department's FCPA enforcement efforts and the current state of corporate compliance.
The DOJ's Pilot Program to encourage companies to self report bribery and cooperate with prosecutors doesn't fix some problems with FCPA investigations and enforcement actions, Lanny Breuer said Wednesday.
Texas-based Lennox International Inc. said in a securities filing Monday that it self reported to the SEC and DOJ an alleged payment of $475 to a Russian customs broker or official.