Emtrain Blog

Why the SEC is Keeping an Eye on Silicon Valley Unicorns

Posted by Janine Yancey

April 28, 2016

In the late 1990s, there was massive investor confidence in companies with little or no earnings, no profits, short track records, and sometimes, no product. As a result, company valuations skyrocketed and a small percentage of people made millions.

Inevitably, the wind started to blow in the other direction and companies were directed to get cash flow positive quickly. That’s when fantasy company valuations plummeted and both employees and investors were left with little to show for their investment of time and money.

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Topics: Compliance, Business Compliance, Code of Conduct, Ethics, ethical workplace culture, Silicon Valley

Strip Clubs & Niagara Falls: Novartis Pays $25 Mil in FCPA Enforcement Action

Posted by Allison Baker

March 28, 2016

This week, the SEC announced a $25 million FCPA enforcement action against Swiss pharmaceutical company Novartis.

Items of value improperly provided to Chinese foreign healthcare professionals by indirect Chinese subsidiaries of Novartis included, among other things, an excursion to Niagara Falls and cover to a strip club.

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Topics: Code of Conduct, FCPA, global anti-bribery, ethical workplace culture

FCPA Enforcement Update: Q1 Enforcement Spree

Posted by Allison Baker

March 7, 2016


The DOJ and SEC have been on a roll the last few weeks. In an unprecedented spree of FCPA enforcement over the past approximate month, eight separate actions have been brought against companies in varying industries such as telecom, pharma, and technology.

The latest of these FCPA enforcement actions against Canadian company Nordion (a global health science company) is notable – it’s the first ever FCPA action against a Canadian company.

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Topics: Code of Conduct, FCPA, global anti-bribery, ethical workplace culture

The High Cost of Leading an Unethical Organization

Posted by Allison Baker

February 23, 2016

Last week, telecommunications company VimpelCom was hit with a $397.5 million FCPA enforcement action for a corporation-wide corruption scheme involving conduct in Uzbekistan.

Coming in at nearly $400 million, this settlement is the 5th largest FCPA settlement amount of all time. Leading an unethical organization comes at a high cost.

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Topics: Code of Conduct, FCPA, global anti-bribery, ethical workplace culture