- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Jaclyn Jaeger2019-10-01T16:22:00
Quad/Graphics will pay $10 million to resolve SEC charges that it violated the Foreign Corrupt Practices Act by engaging in widespread bribery schemes in Peru and China, but the compliance lessons are priceless.
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Walmart, TechnipFMC, Fresenius—just to name a few—have all fallen prey to the Foreign Corrupt Practices Act in a record year of jacked-up enforcement and sky-high penalties.
The Department of Justice in recent months has made several notable revisions to its FCPA Corporate Enforcement Policy surrounding M&A, messaging apps, and much more.
Three former executives of Chicago-based Outcome Health, a healthcare technology company, were sentenced for misleading an auditor, clients, lenders, and investors about a scheme to sell $45 million in overbilled advertisements.
The United States broke from a three-year downturn in bribery-related enforcement actions, while Brazil continued its emergence in the space, according to the results of the latest annual Global Enforcement Report by nonprofit TRACE.
The number of U.S. foreign bribery enforcement actions slowed notably in 2021, while the overall pace of transnational anti-bribery enforcement actions and investigations lagged worldwide, according to TRACE International’s latest enforcement report.
A payment by a U.S.-based company to a third-party intermediary under circumstances that placed an employee’s life and well-being at “significant risk” would not trigger enforcement under the anti-bribery provisions of the FCPA, the Department of Justice stated in an opinion procedure.
