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February 27, 2009

Pride’s Disclosure Tells The Story

We admire Pride International, Inc.’s approach to its Foreign Corrupt Practices Act disclosures. The company talks about the serious problems it had for years with sensitive payments, and how it’s been dealing with them. The countries involved included Venezuela and Mexico, India and Malaysia, Saudi Arabia, Kazakhstan, Brazil, Nigeria, Libya, Angola and the Republic of the Congo, among others. Bribes apparently were paid directly or by intermediaries to clear rigs and equipment through customs, and to help solve problems with immigration, tax, and licensing authorities. Some of the payments in question involved global-logistics firm Panalpina . . . .

Read the entire post at The FCPA Blog   www.fcpablog.com

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February 26, 2009

Extending Compliance To Third Parties

Law.com this week reported the results of a survey conducted by the Society of Corporate Compliance & Ethics (SCCE). The group sent a random survey to compliance professionals about their use of codes of conduct with third parties, such as suppliers, and received back 400 responses. The findings: Fifty-three percent of companies don’t disseminate their internal codes of conduct to third parties; only 26% require third parties to certify to their own codes; and just 17% of the respondents have any third-party codes of conduct to begin with . . .

Read the entire post on The FCPA Blog    www.fcpablog.com

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February 25, 2009

Understanding The KBR, Halliburton Charges

With the Halliburton / KBR settlement in mind, we asked readers last week to help us understand how decisions are made to charge companies or individuals under the Foreign Corrupt Practices Act with violations of the antibribery provisions — criminally or civilly. The best responses, we said, would earn both our gratitude and a copy of Bribery Abroad. We’re sending a copy today to David P. Burns. His comments are below, and they’re great. . . .

Read the entire post at The FCPA Blog    www.fcpablog.com

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February 24, 2009

Following Kozeny’s Money

The Justice Department obtained a federal court order ten days ago against Viktor Kozeny, barring him from touching any of the proceeds from the 2001 sale of his Aspen, Colorado residence, amounting now to about $23 million. The government said the funds came from the money laundering offenses alleged in U.S. v. Kozeny, a federal criminal prosecution in New York that includes Foreign Corrupt Practices Act charges.  . . .

Read the entire post on The FCPA Blog    www.fcpablog.com

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February 23, 2009

Sir Allen And The FCPA

Since hearing about Allen Stanford’s cozy relationships with certain Caribbean leaders, we’ve wondered if he’ll eventually face criminal charges under the Foreign Corrupt Practices Act. Neither bribery nor the FCPA have been mentioned yet in connection with Stanford. But here’s what’s been reported, so far, in the New York Times and elsewhere. . . .

Read the entire post on The FCPA Blog    www.fcpablog.com

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February 20, 2009

The Friday Report, Part Two

The murder of Russian journalist Anna Politkovskaya in 2006 that we talked about earlier this week (here) remains officially unsolved. Yesterday a jury in Moscow acquitted three men charged in her shooting. The LA Times has the story here. On trial were two Chechen brothers and a former Russian police officer. Another man accused in the murder and being tried separately was also released. He’s a member of Russia’s FSB, the domestic successor of the KBG. . . .

Read the entire post on The FCPA Blog    www.fcpablog.com

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The Friday Report

Former Congressman William J. Jefferson says the cash found in his freezer four years ago proves he didn’t violate the Foreign Corrupt Practices Act. Yesterday Jefferson filed a petition for certiorari to the Supreme Court, asking for review of the Fourth Circuit’s refusal to dismiss most of the corruption-related charges against him. But he’s not asking for dismissal of the two Foreign Corrupt Practices Act counts. . . .

Read the entire post on The FCPA Blog     www.fcpablog.com

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February 19, 2009

Waters So Deep

There are things, according to the former Pentagonian, we know we don’t know. But then again, he said, there are things we don’t know we don’t know. That distinction came to mind as we read the latest email from a correspondent who often holds us to a higher standard than we deserve. He said this . . .

Read the entire post at The FCPA Blog   www.fcpablog.com

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February 18, 2009

This Talk Is Not Cheap

Public corruption doesn’t happen in public. It needs dark places to flourish. That’s why the press can play a decisive role in fighting sleaze–just by shining light on it. So the announcement this week by the Chicago Tribune that it’s going all out to fight graft is welcome news. After all, one former Illinois governor, George Ryan, is doing time for a corruption conviction and another freshly impeached former governor, Rod Blagojevich, faces a trial for trying to sell a U.S Senate seat. . . .

Read the entire post at The FCPA Blog    www.fcpablog.com

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February 17, 2009

Protecting The Privilege

Senator Arlen Specter, the ranking Republican member of the Senate Judiciary Committee, has introduced a bill “to provide appropriate protection to attorney-client privileged communications and attorney work product.” S.445 is co-sponsored by Senators Carper (D-DE), Cochran (R-MS), Kerry (D-MA), Landrieu (D-LA) and McCaskill (D-MO) . . . .

Read the entire post on The FCPA Blog    www.fcpablog.com

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