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

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

FCPA Enforcement Starts Off 2016 with a Bang!

Posted by Janine Yancey

February 5, 2016

Last year, when SAP’s Latin American sales leader resolved a parallel DOJ/SEC FCPA enforcement action, the question remained: would there also be an enforcement action against SAP?

Earlier this week, the SEC answered that question by announcing an enforcement action against SAP - the first FCPA enforcement action in 2016.

The SAP action is based on the same core conduct alleged in the prior individual action and the company agreed to pay approximately $3.9 million.

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Topics: FCPA, global anti-bribery, corporate compliance, compliance programs