Tag Archives | Violations

Walmart Fined $282M for FPCA Violation

Yesterday, Walmart entered into a Non-Prosecution Agreement to settle allegations that it violated the Foreign Corrupt Practices by paying an intermediary in Brazil for help obtaining construction permits and operating without a system of sufficient anti-corruption related internal accounting controls in Brazil, China, India, and Mexico.  Walmart Inc. will be required to pay the DOJ […]

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What is corruption? Depends on who’s looking.

By William N. Weaver, originally posted on The FCPA Blog January 29, 2019 (http://www.fcpablog.com/blog/2019/1/29/what-is-corruption-depends-on-whos-looking.html) For those interested in the study of corruption from the scientific perspective one thing stands out: actual corruption is essentially unmeasurable.  It could also be observed that our imperfect measurements of corruption, even more accurate random forced response surveys, have found […]

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Chinese Company Required to Hire U.S. Compliance Officers

In April, ZTE, China’s largest telecommunications equipment manufacturer, was sentenced to a seven year denial of export privileges for illegally shipping telecommunications equipment to Iran and North Korea.  The export denial bars American companies from selling components to the Shenzhen-based company.  ZTE depends on U.S. companies for parts used in its networking gear and smartphones.  […]

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Hottest Industries for FCPA Investigations

A new tool has been launched that tracks open Foreign Corrupt Practices Act (FPCA) investigations.  The FCPA Tracker (https://fcpatracker.com/) scans for and analyzes public disclosures by companies and agencies about FCPA-related investigations.  The top five industries with the most ongoing FCPA-related investigations, according to FCPA Tracker, are: 1. Oil and Gas Services — 24 2. Telecommunications […]

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Bombardier Investigation Illustrates Importance of Doing Your Due Diligence

Bombardier, a company that produces aircraft and train equipment and is headquartered in Montréal, Canada is under scrutiny after one of its sales executives in the Sweden office was arrested. In 2013, the Stockholm-based train division of Bombardier won a $350 million contract to supply Azerbaijan with an interlocking system for railway switches and signals. […]

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Former Diplomat Pleads Guilty in UN Bribery Case

Francis Lorenzo, a U.S. citizen who served as a foreign diplomat from the Dominican Republic pleaded guilty to six charges, including conspiracy, bribery, money laundering, and tax counts, Wednesday in a United Nations bribery case.  Lorenzo agreed to cooperate with the government against co-defendants who include former U.N. General Assembly president John Ashe and Chinese businessmen […]

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Schlumberger Subsidiary Pleads Guilty and Agrees to a $232.7M Penalty for Sanctions Program Violations

Drilling and Measurements (D&M), a Texas-based subsidiary of Schlumberger Ltd. was charged with providing oil field services to Iran and Sudan through overseas subsidiaries of Schlumberger Oilfield Holdings from early 2004 through June 2010.  D&M personnel outside the United States often sent emails to a U.S.-based D&M manager justifying requests for services in Iran and Sudan, […]

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PayPal pays $7.7M Fine for 486 Violations

Over the course of several years, PayPal did not adequately screen its transactions for targets of U.S. Proliferation and Trade Sanctions Programs, and processed transactions equaling approximately $43,000 to denied parties.  The company failed to properly screen transactions with OFAC-sanctioned companies and persons resulting in violations of trade sanctions against Iran, Sudan, and Cuba as […]

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