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Anti-Corruption & Foreign Corrupt Practices Act (FCPA)

  • Shearman & Sterling's Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA)/FCPA Digest

    5 Jan 2015
    Shearman & Sterling’s bi-annual Trends & Patterns report provides insightful analysis of recent enforcement trends and patterns in the US, the UK, and elsewhere as well as helpful guidance on emerging best practices in FCPA and global anti-corruption compliance programs.
  • Gifts of Travel and Luxury Watches to Saudi Officials Not Mere 'Icing on the Cake' for FCPA Charges

    21 Nov 2014
    Earlier this week, the SEC announced fines for two former defense contractor employees for FCPA violations relating to gifts given to Saudi officials. The individuals, Stephen Timms and Yasser Ramahi, each consented to the entry of settled administrative proceedings and agreed to pay $50,000 and $20,000 in fines, respectively. According to the SEC, in 2008 and 2009 the two men (employees of Boston-based FLIR Systems, Inc. at the time and each a US citizen) gave Saudi officials luxury watches and a 20-night multi-continent trip to win contracts for binoculars and security cameras. This enforcement action is noteworthy for being one of very few premised solely on improper gifts.
  • SEC Settlement with Layne Christensen Raises New Questions on the Government’s Understanding of the Business Nexus Element of the FCPA

    4 Nov 2014
    Last week the SEC settled charges against Layne Christensen for various violations of the FCPA. While a relatively unremarkable case at first glance, the SEC’s charges against Layne Christensen reflect a troubling approach by enforcement agencies to disregard the “business nexus element” of the FCPA’s anti-bribery provisions. These recent practices appear to contradict the Fifth Circuit’s opinion in United States v. Kay and create greater uncertainty as to the scope of the statute.
  • Sanctions Round-Up: Third Quarter 2014

    20 Oct 2014
    The third quarter of 2014 was marked by the issuance and then significant expansion of U.S. and E.U. sanctions targeting specific sectors of the Russian economy. These sectoral sanctions complement ongoing efforts by both jurisdictions to identify and designate persons contributing to the ongoing instability in eastern Ukraine.
  • Russia Sanctions: Impact on Financial Institutions in the US, EU and Japan

    25 Aug 2014

    New sanctions targeting Russia have been implemented in the US, EU and Japan. Although the consequences of breaching the sanctions are severe, navigating the rules is not straightforward. Transactions and business lines will need to be reconsidered in light of the complex rules to which they may be subject. This client publication highlights the key issues and differences in the US, EU and Japanese rules that companies should understand.

  • Shearman & Sterling's Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA)/FCPA Digest

    21 Jul 2014
    Shearman & Sterling’s bi-annual Trends and Patterns report provides insightful analysis of recent enforcement trends and patterns in the US, the UK, and elsewhere as well as helpful guidance on emerging best practices in FCPA and global anti-corruption compliance programs. While the first half of 2014 brought relatively fewer corporate enforcement actions, higher than average penalties, increased individual prosecutions, and several developments in ongoing cases have provided insights into evolving enforcement trends.
  • Sanctions Round-Up: Second Quarter 2014

    9 Jul 2014

    The headline for the second quarter is, of course, the United States’ enforcement action against Bank BNP Paribas and its breathtaking penalty of $8.9 billion, tied to the allegedly intentional evasion of the US sanctions programs for Sudan and, to a lesser extent, Iran and Cuba. This settlement capped off a series of enforcement actions by US authorities against a variety of actors stemming from violations of all sizes.

  • So You Want to See Messi, Neymar, Ronaldo, and Xavi: Brazil Issues Directive Barring Government Officials From Receiving World Cup Tickets

    2 Jun 2014
    Earlier today, the Comptroller’s Office in Brazil, Controladoria-Geral da União (“CGU”), issued a sweeping directive barring government officials from accepting offers to attend or participate in the upcoming 2014 FIFA World Cup events set to begin in Brazil on June 12, 2014.
  • OFAC Settles Civil Enforcement Action with Dutch Company for Alleged Violations of US Trade Embargo on Cuba

    25 Apr 2014
    The US Treasury’s Office of Foreign Assets Control (OFAC) and Carlson Wagonlit Travel (i.e., CWT B.V.), a Netherlands-based company, have agreed to settle violations of the Cuban Assets Control Regulations (CACRs) dating back to as early as August 2006.
  • Sanctions Round-Up: First Quarter 2014

    3 Apr 2014
    The first quarter of 2014 opened with a continued focus on Iran, as US authorities somewhat contradictorily took steps both to ease certain Iranian sanctions, as agreed under the Joint Plan of Action, and to target a number of additional Iranian persons under existing sanctions.
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