On June 16, 2016, Teva Pharmaceutical’s Russian subsidiary (Teva LLC) pled guilty to one count of conspiring to violate the Foreign Corrupt Practices Act (FCPA). Judge Kathleen M. Williams of the United States District Court for the Southern District of Florida hesitated, however, in
In 2008, global technology giant Siemens Aktiengesellschaft (“Siemens”) pleaded guilty to violations of the books and records provision of the Foreign Corrupt Practices Act (“FCPA”). Siemens paid approximately $450 million in fines for its alleged violations and another $350 million to settle a civil suit brought by the US Securities and Exchange Commission. In addition,
In a complaint recently filed in Delaware Chancery Court, a shareholder of General Cable Corp. (“General Cable”) has asked the Court to compel the release of documents related to General Cable’s $82 million settlement of claims under the Foreign Corrupt Practices Act (FCPA).
In
In a pair of recent articles (available here and here), practitioners have been crunching the numbers, and 2016 is on near-record pace for Foreign Corrupt Practices Act (FCPA) enforcement action dispositions. Through October, 2016 has seen 39 FCPA enforcement actions resolved, a pace that would have government agencies end the year with 48-plus dispositions
UK-Based biopharmaceutical company AstraZeneca agreed to pay the U.S. Securities and Exchange Commission (SEC) $5.5 million to settle claims that its Chinese and Russian subsidiaries had made improper payments to state-controlled health care providers in violation of the Foreign Corrupt Practices Act (FCPA).
In an order released earlier this week, the SEC outlined both the
AstraZeneca will pay $5.5M to the Securities and Exchange Commission to settle claims that it violated the Foreign Corrupt Practices Act by making improper payments to state controlled health care providers in China and Russia.
Background
The SEC complaint provides that the staff of AstraZeneca’s foreign
subsidiaries bribed health care providers in China and Russia
Earlier this year, the US Department of Justice announced a one-year pilot program under which US corporations could mitigate their own liability for violations of the Foreign Corrupt Practices Act (FCPA) by voluntarily self-disclosing FCPA violations within their organization, in addition to fully cooperating with DOJ investigations and taking steps to remediate any misconduct. Skeptics,
The U.S. Securities and Exchange Commission has agreed to a $28 million settlement with software producer PTC, Inc. following allegations of bribes paid to Chinese officials between 2006 and 2011 in violation of the Foreign Corrupt Practice Act (FCPA).
In the administrative proceeding (No. 3-17118), the SEC alleged that two of PTC’s Chinese subsidiaries bribed
SCS Corporation, Ltd. (SCS), a unit of Houston oil and gas drilling company Hyperdynamics Corporation (“Hyperdynamics”), has filed parallel actions in the Southern District of Texas (4:16-cv-00076) and before the American Arbitration Association against two partners who SCS alleges used an FCPA investigation into Hyperdynamics as a pretext for breaching their joint exploration agreement.
SCS
Although the number of FCPA enforcement actions by the Securities and Exchange Commission (SEC) and Department of Justice (DOJ) are down in 2015, a recent report indicates the the third quarter saw twice as many FCPA claims resolved as the first two quarters of 2015 combined.
There does not appear to be a clear single