- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
Tom Fox explores the term “conscious avoidance” under the FCPA, specifically in the case of Frederick Bourke, who invested in an enterprise in Azerbaijan that was engaged in bribery and corruption to obtain certain oil and gas rights of which Bourke claimed he had no knowledge.
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Whether you’re a multinational telecommunications company looking to certify your anti-corruption program post-settlement, or a biochemical company victimized by a “rogue” employee, seeing the light at the end of the enforcement tunnel isn’t always easy.
Aviation maintenance services provider AAR Corp. will pay nearly $56 million to settle charges that it violated the Foreign Corrupt Practices Act when it paid bribes to government officials in Nepal and South Africa.
A subsidiary of McKinsey & Co. will pay nearly $123 million to the Department of Justice to settle allegations that it bribed officials in South Africa to win consulting contracts.
