Policy Patty Toolkit 

Making the world a little more compliant one toolkit at a time.


China Amends Its Anti-Corruption Law

Posted on November 15, 2018 at 8:25 AM

As reported in the FCPA Blog recently, China has amended its Criminal Procedure Law (CPL) to codify rules encouraging cooperation in government investigations, align with the new national supervision system, and introduce trials in absentia for certain crimes, including bribery and corruption. The amendments took effect immediately on October 26, 2018. 

Highlights of the changes include:

1. Codified leniency rules in criminal guilty pleas.

2. Revised procedures for inv...

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Businessman Indicted for Conspiring to Bribe Senior Government Officials of the Republic of Haiti

Posted on October 31, 2018 at 10:30 AM

Roger Boncy, a business man based in Madrid, Spain was named in a superseding indictment along with co-defendant Joseph Baptiste, a resident of Maryland. The indictment alleges one count of conspiracy to violate the Foreign Corrupt Practices Act and the Travel Act, one count of violating the Travel Act and one count of conspiracy to commit money laundering.

The charges are based on allegations that Messrs. Boncy and Baptiste:

  • Solicited bribes from undercover agents posin...
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SEC Actions for September 12-13, 2018

Posted on September 14, 2018 at 9:30 AM

The Securities and Exchange Commission (SEC) news for 09/12-13/2018 includes the following appointments and actions:

United Technologies Charged with Violating FCPA

• The SEC announced that Connecticut-based United Technologies Corporation will pay $13.9 million to resolve charges that it violated the Foreign Corrupt Practices Act (FCPA) by making illicit payments in its elevator and aircraft engine businesses.

• According to the SEC’s order, United...

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Sanofi Charged With FCPA Violations

Posted on September 5, 2018 at 9:25 AM
The SEC announced that Paris-based pharmaceutical company Sanofi has agreed to pay more than $25 million to resolve charges that its Kazakhstan and the Middle East subsidiaries made corrupt payments to win business. According to the SEC's order: 1) The schemes spanned multiple countries and involved bribe payments to government procurement officials and healthcare providers in order to be awarded tenders and to increase prescriptions of its products. 2) In Kazakhstan, distributors were use... Read Full Post »

SEC Charges Legg Mason With Violating the FCPA

Posted on August 27, 2018 at 8:00 PM

The SEC announced that Legg Mason Inc. will pay over $34 million to resolve an SEC charge that the company violated the Foreign Corrupt Practices Act (FCPA) in a scheme to bribe Libyan government officials.

According to the SEC’s order:

  • Between 2004 and 2010, a former Legg Mason asset management subsidiary, Permal Group Inc., partnered with a French financial services company to solicit investment business from Libyan state-owned financial institutions. 
  • Th...
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SEC Charges Credit Suisse With FCPA Violations

Posted on July 6, 2018 at 8:20 AM

The SEC charged Credit Suisse Group AG with violations of Foreign Corrupt Practices Act (FCPA) and will pay approximately $30 million to resolve charges that it obtained investment banking business in the Asia-Pacific region by corruptly influencing foreign officials.

Credit Suisse also agreed to pay a $47 million criminal penalty to the U.S. Department of Justice.

According to the SEC’s order:

  • Several senior Credit Suisse managers in the Asia-Pacific region sough...
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SocGen Agrees to Pay $60 Million for Libya Bribery Case

Posted on June 4, 2018 at 1:20 PM

Société Générale S.A. agreed to pay $860 million in criminal penalties for bribing Gaddafi-Era Libyan officials and manipulating LIBOR Rate. The bank admitted to making over $90 million in corrupt payments and acknowledged manipulation of global benchmark interest rate, impacting financial products traded worldwide.

The settlement represents a coordinated enforcement action by the DOJ and French authorities in an overseas corruption case. As a result, ocGen will:

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DOJ Charges Two More in Rolls Royce Bribery Case

Posted on May 29, 2018 at 8:10 AM

The U.S. Department of Justice (DOJ) charged a former Armenian ambassador and a Russian national with being part of a bribery scheme to help an Ohio-based unit of Rolls Royce win an overseas pipeline contract. Azat Martirossian and Vitaly Leshkov were charged in a superseding indictment filed in federal court in Ohio. While both are believed to be living outside of the U.S., they face one count of conspiracy to launder money and 10 counts of money laundering.

This matter follows the 201...

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Panasonic Charged With FCPA and Accounting Fraud Violations

Posted on April 30, 2018 at 4:55 PM

The SEC settled charges against Japan-based Panasonic Corp., which will pay more than $143 million to resolve charges of Foreign Corrupt Practices Act (FCPA) and accounting fraud violations involving its global avionics business.

The settlement focused on the following alleged actions:

  • Panasonic’s U.S. subsidiary, Panasonic Avionics Corp. (PAC), a provider of in-flight entertainment and communication systems, offered a lucrative consulting position to a government offic...
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Kinross Gold Charged with FCPA Violations

Posted on March 26, 2018 at 6:30 PM

The SEC settled an action against Canada-based Kinross Gold Corporation for Foreign Corrupt Practices Act violations arising from the company’s repeated failure to implement adequate accounting controls of two African subsidiaries. Per the order, Kinross Gold acquired the African subsidiaries in a $7.1 billion transaction in 2010, understanding that the subsidiaries lacked anti-corruption compliance programs and internal accounting controls. Kinross Gold implemented FCPA controls over...

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