Sunday, November 14, 2010

DOJ Settles Seven FCPA Cases and Announces New Minimum Standards for Corporate FCPA Compliance Programs

Michael Volkav of Mayer Brown writes:

The Department of Justice and Securities and Exchange Commission (SEC) resolved seven FCPA cases last week involving the oil and gas industry.  The cases involved bribes to numerous foreign officials relating to the import of goods and materials in foreign jurisdictions.  To resolve the investigations each company entered into a deferred prosecution agreement and a total of nearly $122 million in fines were paid. 

Each of the Deferred Prosecution Agreements included an attachment entitled “Corporate Compliance Program,” which reflect DOJ’s current position on minimum standards for FCPA compliance programs.  The standards require, among other things,

i.       clearly articulated and visible policies against violations of the FCPA,

ii.      visible corporate support of such policies,

iii.     implementation of compliance standards and procedures designed to reduce FCPA violations, and

iv.     the assignment of responsibility for the implementation and oversight of such policies, standards and procedures to “one or more senior corporate executives.”

 (mv)

http://lawprofessors.typepad.com/whitecollarcrime_blog/2010/11/doj-settles-seven-fcpa-cases-and-announces-new-minimum-standards-for-corporate-fcpa-compliance-programs.html

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Comments

Out sourced compliance should be mandatory.

Posted by: Form ADV | Nov 14, 2010 2:24:16 PM


This is a great blog document and much needed in ensuring that projects lead to value. It would be of great help to have some generic examples of benefit maps etc included in the guideline. I have just started out in the benefits management areana, find it very useful, but am still finding my feet on the practical application.

Posted by: Stock tips | Nov 17, 2010 10:05:22 PM

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