Emtrain Blog

NEW! Global Anti-Bribery and Corruption Course Update

Posted by Allison Baker

March 22, 2017

Bribery & corruption training has never been more critical to the global market than it is today. From 2015 to 2016, FCPA-related enforcement actions by the SEC have increased by 163%.

Are your employees trained to spot behavior that may trigger enforcement?

Our newly updated Global Anti-bribery and Corruption course authored by FCPA expert, Mike Koehler, provides employees with an overview of FCPA compliace, OECD, and the U.K. Bribery Act.

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Topics: FCPA, global anti-bribery

Happy National Drink Beer Day, Now Give the SEC $6 Mil!

Posted by Allison Baker

September 29, 2016

Yesterday, on National Drink Beer Day, no less, the SEC filed a cease and desist order against Anheuser-Busch InBev for violating the FCPA’s books and records and internal controls provisions.

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Topics: Compliance, Business Compliance, Corporate Governance, FCPA

UK-Based AstraZeneca Pays $5.5 to Settle FCPA Enforcement Action

Posted by Allison Baker

September 2, 2016

Earlier this week, the SEC announced a $5.5 million enforcement action against AstraZeneca based on the actions of its foreign subsidiaries.

The action stems from an almost decade-old issue involving the UK-based company providing various items of value to Russian and Chinese physicians via foreign subsidiaries.

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Topics: Compliance, Business Compliance, Corporate Governance, FCPA

Key Energy Services Resolves FCPA Enforcement Action for $5 million

Posted by Allison Baker

August 17, 2016

 

Key Energy Services was found liable for FCPA books and records and internal controls violations, even though the SEC found that certain employees of an indirect Mexico subsidiary “abused their privileges, approving suspect arrangements with and payments to consultants and gifts to Mexican government officials at Pemex, and concealing these arrangements and payments from Key Energy.”

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Topics: Compliance, Business Compliance, Corporate Governance, FCPA

FCPA Enforcement: LAN Airlines Pays $22 Million to Settle FCPA Charges

Posted by Allison Baker

July 28, 2016

 

Earlier this week, LATAM / LAN airlines, a Chilean company, paid the U.S. government $22 million in an FCPA enforcement action related to an Argentine labor dispute.

The FCPA enforcement action against LATAM / LAN airlines was an extension of the February 2016 enforcement action against current LATAM CEO Ignacio Plaza.

The enforcement action is interesting for a few reasons:

  • The initial violation occurred 10 years ago on foreign soil.

  • There were no actual anti-bribery charges. Rather, the charges were for violations of the FCPA's books and records and internal controls provisions - provisions applicable to the Chilean company because it has shares traded on a U.S. exchange.

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Topics: Compliance, Business Compliance, Corporate Governance, FCPA

Are Distributors Putting You at Risk for an FCPA Violation?

Posted by Allison Baker

June 30, 2016

 

Last week, the DOJ and SEC announced a parallel FCPA enforcement action against medical device manufacturer Analogic Corp. and BK Medical ApS (Analogic’s Danish subsidiary) in which the entities agreed to pay approximately $14.9 million.

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Topics: Compliance, Business Compliance, Corporate Governance, FCPA

Why It's Important to Translate Your FCPA Compliance Training

Posted by Allison Baker

June 9, 2016

 

Two FCPA actions brought by the SEC stem, in part, from a similar issue: failure to offer FCPA compliance training in the appropriate language. In these two particular cases, the language in question is Mandarin.

The two actions are unrelated, but bring to light a very common issue in compliance. The actions against Nortek Inc. and Akamai Technologies are a reminder for organizations to offer FCPA compliance training to regions of risk in the native tongue.

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Topics: Compliance, Business Compliance, Corporate Governance, FCPA

FCPA Enforcement News: What You Need to Know From Q1

Posted by Allison Baker

April 8, 2016


The following post was adapted from a blog post written by our contributing editor, Professor Mike Koehler, and a version of it originally appeared on his FCPA Professor website. Professor Koehler developed our Global Anti-Bribery and Corruption course.

If you've been paying attention to FCPA enforcement news over the last few months, it's no surprise that the list of Q1 actions is a long one.

Keep reading for a full summary of Foreign Corrupt Practices Act enforcement activity and related developments from the first quarter of 2016.

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Topics: Compliance, Business Compliance, Corporate Governance, FCPA

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