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Top Ten SEC and CFTC Recoveries of 2023

Posted  01/24/24
Foreign Exchange Graph
It was an active year for fraud enforcement at the Securities and Exchange Commission (SEC) and Commodities Futures Trading Commission (CFTC).  Though by no means was it a record year for either regulator in terms of big-ticket wins.  Aside from the CFTC's $1.7 billion recovery from South African crypto company Mirror Trading for foul play with foreign currency transactions, the balance of the Top-10 recoveries was...

Top FCPA Recoveries of 2023

Posted  01/19/24
Mix of Foreign Currency Scattered Around
The Foreign Corrupt Practices Act (FCPA) bars payments to foreign officials for any kind of business advantage, such as securing government contracts or other kinds of favorable business treatment.  The statute covers any form of consideration including gifts, meals, travel, and entertainment.  It also imposes strict record-keeping and internal control requirements to prevent falsifying company books and records...

Catch of the Week: SAP SE

Posted  01/16/24
Briefcase Full of Money
This week's Department of Justice (DOJ) Catch of the Week goes to SAP SE (SAP).  On Wednesday (January 10), the German-based software company agreed to pay roughly $220 million to settle DOJ and SEC charges of violating the Foreign Corrupt Practices Act (FCPA) through bribes to government officials in South Africa and Indonesia. The FCPA bars payments to foreign officials for any kind of business advantage, such...

Catch of the Week: Freepoint Commodities

Posted  12/18/23
Government contract fraud whistleblower
This week's Department of Justice (DOJ) Catch of the Week goes to Freepoint Commodities.  Last Thursday (December 14), the Connecticut-based commodities trading company agreed to pay roughly $98 million to settle government charges it violated the Foreign Corrupt Practices Act (FCPA) by paying bribes to Brazilian government officials.  The company also agreed to disgorge roughly $7.6 million to the Commodity Futures...

3M to Pay $6.5 Million for Foreign Bribery Charges

Posted  08/29/23
Businessman Examining Books and Records
On Friday (August 25), the Securities and Exchange Commission (SEC) announced that Minnesota-based global manufacturer 3M Company agreed to pay $6.5 million to settle SEC charges of violating the Foreign Corrupt Practices Act (FCPA).  According to the SEC Order finalizing the settlement, the SEC found that employees of 3M's wholly-owned Chinese subsidiary provided improper consideration to Chinese officials of...

Top Ten FCPA Recoveries of 2022

Posted  01/13/23
International Currency
In recent years, the United States government has recovered billions of dollars going after companies that bribe foreign officials in order to further their business interests, a practice that violates the Foreign Corrupt Practices Act (FCPA). Two principal United States government agencies, the Department of Justice and the Securities and Exchange Commission, investigate and prosecute FCPA violations. Whistleblowers...

America’s Whistleblower Programs are a Beacon for International Whistleblowers

Posted  09/28/22
Global Map
Constantine Cannon whistleblower partner Mary Inman and associate Liz Soltan wrote a guest post for the Taxpayers Against Fraud blog about the role of international whistleblowers in providing an increasing number of tips under the various American whistleblower reward programs. The U.S. leads the world in enlisting whistleblowers as force-multipliers to help law enforcement and regulators detect and root out fraud...

Stericycle Pays More than $84 Million to Settle FCPA Charges

Posted  04/26/22
Man Shaking Hand
Last Wednesday, Illinois-based waste management company Stericycle Inc. agreed to pay more than $84 million to settle foreign bribery charges brought in parallel by the Department of Justice (DOJ), the Securities and Exchange Commission (SEC), and authorities in Brazil. The charges centered around payments Stericycle made to foreign officials in Brazil, Mexico, and Argentina to secure government contracts in those...

Top FCPA Recoveries of 2021

Posted  01/14/22
desk globe
We wish we could provide a list of the Top Ten FCPA recoveries of 2021.  But, in 2021, there were just four FCPA settlements announced by government enforcement agencies.  Following back-to-back years with billions of dollars in recoveries under the Foreign Corrupt Practices Act in 2020 and 2019 momentum has, unfortunately, stalled. The FCPA prohibits the payment of bribes to foreign officials made with the...

Top Ten FCPA Recoveries of 2020

Posted  01/27/21
globe
2020 was a blockbuster year in the U.S. government’s battle against companies and individuals enmeshed in foreign bribery schemes.  The list of 2020's largest settlements involving charges under the Foreign Corrupt Practices Act (FCPA) includes many substantial recoveries. In 2020 the government recovered billions of dollars in settlement of claims under the FCPA, building on substantial recoveries just last...
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