#fcpa fraud law firm

[marketminglemaster]

7 KPIs That Increase Online Visibility for Whistleblowers

With more and more businesses putting their focus on digital marketing, it is more important than ever to have a solid online presence if you want to drive leads and attract potential whistleblowers. Whistleblower law firms may reach more people and help those in need by using digital channels like websites, social media, and search engines effectively.

As a means of measuring their digital effectiveness, whistleblower law firms should aim to increase their online presence and generate leads from whistleblowers. Online visibility can be better understood with the use of these indicators, which shed light on things like website traffic, social media engagement, and search engine results, among others. Whistleblower law firms can strategically position themselves to attract and engage potential whistleblowers by studying and optimizing these criteria.

1. The Amount of Visitors to the  Whistleblower Website

Indicative of the interest and engagement sparked by a website's content and offerings, it represents the number of visitors accessing the site. By analyzing website traffic, whistleblower law firms may gauge their digital marketing efficacy, reach, and online visibility, pinpointing where they can make improvements to draw in additional clients.

To gauge how well their websites are doing, whistleblower legal companies can monitor indicators like total visits, page views, and bounce rates. Companies can maximize the effectiveness of their marketing campaigns by focusing on the channels that generate the most revenue by analyzing the sources of their traffic. Analyzing user activity, businesses may improve their online presence, make information more relevant and effective, and meet the demands of potential whistleblowers.

2. Visibility of Whistleblower in Search Engines

Raising the firm's website to the top of relevant search engine results pages (SERPs) raises its profile and makes it more likely that potential whistleblowers will find it during their searches. For the FCPA fraud law firm, tracking keyword rankings and monitoring organic search performance are crucial activities. Businesses may improve their SEO tactics to rank higher and receive more quality leads by tracking the performance of specific keywords and the amount of engagement they generate with their target audience.

Firms may increase their authority and relevance in search engines by implementing techniques like optimizing website content, upgrading website structure and navigation, and developing high-quality backlinks. Optimizing Google My Business listings and obtaining citations from trustworthy directories are examples of local SEO methods that can further increase a firm's exposure in its target geographic area.

3. Engaging with Social Media to Increase Online Visibility of Whistleblower

Metrics such as followers, likes, shares, and comments form the backbone of digital marketing strategy. You may learn a lot about how engaged and moved a brand's or organization's audience is by looking at these measures. Businesses may get a good idea of how well their content and outreach are doing by keeping an eye on social media activity and analyzing it to see which posts get the most likes and comments.

Making material that is interesting, useful, and aesthetically pleasing can attract viewers and get them involved. This may be done by replying to comments, answering questions, and starting meaningful conversations. Some other techniques that can be used to boost social media engagement and audience participation include holding contests or giveaways, posting user-generated material, and interactive question and answer sessions.

4. The Effectiveness of Content

Important signs of the efficacy and influence of content marketing campaigns are content performance metrics. Page views, time on page, and bounce rate are some of the indicators that businesses can use to evaluate the engagement levels and content efficacy. The amount of page views is a good indicator of the reach and popularity of a piece of content since it shows how many times the content has been accessed. An indicator of how engaging and relevant a piece of material is to its target audience is the average amount of time that visitors spend on a page.

If you want your content to function at its best, you need to make sure it's educational and of good quality and geared toward the interests and demands of your target audience. Positioning the organization as an authority in their sector can be achieved by customizing content to address relevant themes and industry-specific difficulties. Content produced by the respiratory fraud law firm can enlighten readers regarding typical forms of fraud, how to comply with regulations, and the rights of whistleblowers. 

5. Creating Leads for Whistleblower

You can learn a lot about how well your lead generation initiatives are doing by looking at metrics like conversion rate, lead quality, and cost per lead. The conversion rate is the proportion of leads that go through to the intended action, like requesting further information or signing up for a newsletter. Lead quality is a metric for evaluating how well produced leads meet the criteria of the target market and ideal client profile.

Businesses need to use focused techniques that are specific to their audience and goals if they want to increase conversion rates and optimize lead generation campaigns. Finding the best sources and strategies for online lead tracking by monitoring leads generated through several channels such as social media, email marketing, and search engine optimization (SEO). To take advantage of their knowledge of digital marketing, audience targeting, and campaign optimization, a respectable New York social media agency may be a great asset to lead generation efforts.

6. Internet Cultivation  for Whistleblower

The impression that a whistleblower law firm gives to prospective clients is heavily impacted by metrics like ratings and reviews on social media channels and platforms like Google My Business. High ratings and positive reviews demonstrate the firm's professionalism and dependability, which might reassure potential customers. Emphasizing the significance of preserving a positive online reputation, it is crucial to avoid negative feedback or low ratings as these can discourage leads from contacting the organization.

Companies can reduce reputational risks by actively responding to comments and suggestions, which shows that they care about being transparent and happy customers. Further strengthening the firm's online reputation and showcasing its strengths and success stories can be achieved by using techniques to solicit and exhibit good evaluations. Maintaining credibility and trustworthiness in the eyes of prospective whistleblower leads is essential for managing and improving one's internet reputation.

7. Real-Life Instances to Increase Online Visibility of Whistleblower

Prospective customers may see the real results of these indicators in action by seeing how other businesses have used them to boost their web presence and bring in new business. Other whistleblower law firms, like those in DC, can learn a lot from case studies on how to increase their web presence and generate more leads.

Aspiring businesses can learn a lot by studying the tactics used by successful companies and the quantifiable results they get. With these tools at its disposal, the whistleblower law firm can craft individualized plans that address their specific demands. Firms can achieve their goals of obtaining whistleblower leads by using case studies as informative and inspirational materials.

Wrap Up on  7 KPIs That Increase Online Visibility for Whistleblowers

By tracking key performance indicators including organic search traffic, keyword rankings, website engagement, social media interactions, content performance, backlink profile, and conversion rates, these businesses may understand how their audience engages with their online presence. With the use of these metrics, whistleblower law firms may improve their digital marketing tactics, increase their online presence, and get more leads from whistleblowers.

When it comes to lead generation and internet exposure, whistleblower law firms should pay close attention to the metrics that matter the most. To improve their online lead generation and conversion rates, whistleblower law firms should use data-driven strategies and tweak their methods on a regular basis. Whistleblower law firms can position themselves for long-term success in the digital landscape of whistleblower reporting by taking a disciplined strategy to measure and optimize these KPIs.

[bonjourmoncher]

Plaintiff Lawyers Join The Bribery Racket The Justice Department’s unprecedented campaign to enforce a once-backwater statute called the Foreign Corrupt Practices Act, or FCPA, has made corporate lawyers and accountants rich as big companies pay big law and accounting firms to investigate and defend potential violations. Plaintiff lawyers have noticed the enormous fees, which are often reaching into the hundreds of millions of dollars, enhanced FCPA enforcement is generating and are moving to extract their own cut.

"We are seeing a variety of civil lawsuits that we s

The unintended consequences of the Justice Department’s FCPA policy simply continue to mount. The intense criminalization by U.S. government lawyers of behavior that should never be condoned, but is globally systematic, has produced many outcomes. Meet one of them: Hamilton Lindley, a professional securities class-action lawyer. In the last few months he has followed corporate disclosures of FCPA investigations by suing the boards of directors of Weatherford International, Parker Drilling, Avon Products and Pride International. Lindley is now spending a quarter of his time on the FCPA and is quite honest in saying he is just following the lead of the Department of Justice and the Securities & Exchange Commission. “I think the fact that these companies have been committing graft overseas frankly is an interesting topic for juries to hear,” Lindley told me. “It’s the new enforcement regime of the DOJ and SEC so private practice lawyers are interested in what government lawyers are doing.”

In the lawsuit Lindley filed against Weatherford and its board, for example, Lindley has figured out by taking a few minutes to read an SEC filing that the “Weatherford Board has incurred an astonishing $108 million in costs and expenses in connection with FCPA-related investigations,” which doesn’t include the “pecuniary penalty that Weatherford is likely to have to pay to resolve the DOJ and SEC investigations.” So the general idea is for Lindley and his firm, Goldfarb Branham, to also make some money off of Weatherford’s conduct.

As I wrote a few months ago, all this stems from Weatherford’s voluntary disclosure in 2007 that it might have a small bribery problem in Europe. It hired law firm Fulbright & Jaworksi to conduct an investigation, which became long and expensive— and uncovered additional potential bribery all the way in West Africa. One Fulbright lawyer, William Jacobson, who happened to have been assistant chief of the Department of Justice’s office responsible for FCPA enforcement when Weatherford made its initial disclosure, became a general counsel at Weatherford, though the company says he has been walled-off from the investigation.

Now the plaintiff lawyers are trying to join the fun. So far the results have been mixed as plaintiff lawyers try to get around the fact that the FCPA does not really provide directly for civil actions. Shareholder actions based on securities fraud or breaches of fiduciary duty by boards of directors seem to be popular. According to Miller Chevalier, plaintiff firms have extracted FCPA-related settlements in civil litigation from companies like Faro Technologies, which paid $6.9 million; Nature’s Sunshine, which paid $6 million, Immucor, $2.5 million; and Syncor, $15.5 million.

How much do the plaintiff lawyers wind up with? In the Syncor case plaintiff firms Dietrich & Arleo, Kendall Law Group, and Coughlin Stoia got 25% of the settlement, or $3.87 million, a court filing shows. How disproportionate can the civil litigation get? In the Faro Technologies case, in which the company self-reported the violations, plaintiff lawyers settled for $6.9 million, even though Justice and the SEC got just $2.9 million, court documents show. How much more baffling can copycat FCPA civil litigation be for the board of directors of a company? Pretty baffling when you consider the Justice Department-mandated compliance monitor making millions of dollars following a Justice Department FCPA settlement doesn’t appear to be working under attorney-client privilege. The monitor might have to turn all the secrets he is being paid to uncover by the company that has been forced to hire him right over to a plaintiff’s attorney who is suing the same company.

There is still no evidence that the Justice Department’s aggressive FCPA effort—the many FCPA actions it has brought in the last few years coupled with 150 open FCPA investigations—is having any impact reducing bribery. There is some anecdotal evidence, however, that it is disadvantaging U.S. corporations in the global marketplace. FCPA cheerleaders were pretty convinced recently the U.S. wouldn’t be virtually alone in the world in enforcing anti-bribery laws, encouraged by the U.K.’s adoption of an actual anti-bribery law. But like most OECD countries, the U.K. has now revealed it has little intention of actually enforcing the law anytime soon. There is also now an indication that an individual or company can be exempt for political reasons from the serious consequences now associated with FCPA enforcement.

What is clear is that the cost of enhanced FCPA enforcement on U.S. corporations keeps going up. And that more lawyers are finding ways to get rich off of it.

[sciforce]

Artificial Intelligence to Fight Fraud and Corruption

Corruption and fraud have been on the agenda since the dawn of the statehood and with the development of markets penetrated the business. Both states and companies have been fighting with financial crime and corruption for years: the United States, for example, aggressively enforce the Foreign Corrupt Practices Act (FCPA) and impose significant sanctions on corporations and individuals. Other countries are also passing new anti-bribery laws, such as Sapin II in France, or stepping up enforcement of existing laws. In today’s globalized world, prosecutors and regulators are working more closely across borders to share information. In this environment, it is likely that a company with a bribery/corruption problem will be facing investigations in multiple jurisdictions. To curb bribery and corruption, and remain compliant, companies are seeking out new technology solutions to manage what was often relegated as an employee management issue.

However, traditional solutions still lack effectiveness in:

Detecting accounting misappropriations;

Matching receipts, invoices, expense payouts against travel and self-reported databases, and, most prominently,

Processing natural language or unstructured data sets such as emails or text messages.

The next step in protecting against financial crime would be to leverage advancements in artificial intelligence (AI), and data analytics hoping that technology-assisted data analysis can provide the diligence and reliable quality control needed to provide governments and businesses with conclusions that can be trusted.

How AI helps

Now, with the vast amount of data we live in, it is believed that appropriate data analytics coupled with AI techniques can analyze data quickly from multiple sources and identify anomalous activity associated with third parties, employees, and customers.

In particular, Artificial Intelligence can:

sort text messages, audio files, emails and other unstructured data into manageable groups, making use of structured and unstructured data;

recognize patterns of frequency or timing, as well as detect anomalous activities;

predict future risks and suspicious activities.

Some of the AI techniques used to identify financial crime risks include advanced entity resolution and verification, Ultimate Beneficial Owner analysis, deep Web analytics, NLP (Natural Language Processing) Web scraping, network analysis, and volumes and values analysis.

Data Problem

Data is kept in structured and unstructured formats. Structured data is essentially kept in an accounting or enterprise resource planning (ERP) system, such as SAP or Oracle to record all transactions that have been undertaken. Legal teams can work with a forensic accounting firm to define a set of data analytic tests that can be run to show basic fraud or corruption criteria.

Unstructured data includes text messages, emails, messaging apps (eg, Viber and WhatsApp) and other types of point-to-point encrypted communication and it essentially reflects the way people use communications systems. Unstructured data is practically useless for analysis of any kind without preprocessing and fitting into particular categories. Such processing of unstructured data is one of the key tasks of Natural Language processing.

Besides, NLP analysis can identify a number of keywords in the employee’s emails and texts that indicated guarantees and suspicious foreign payments. As a first step fraud concepts are identified by domain experts. A fraud concept may be a person, a characteristic, an entity, or an event that represents a suspicious scenario and it is represented by words, phrases, entities, etc. The presence of these words/phrases in the document implies occurrence of fraud concept in that transaction. The end result of this exercise will be a fraud dictionary that is a repository of concepts and suspicious key words. Afterwards, phrases and keywords in the transaction are semantically matched with phrases or keywords in the fraud dictionary to identify fraud concepts present in the text.

Anomaly detection

Detecting suspicious activity against normal transactions is the ultimate goal of all AI-driven solutions addressing the problem of fraud and corruption. In simple words, working through accounting ledgers, travel and expense reports, receipts and invoices, emails, phone calls, and text messages, AI helps detect patterns are too complex for humans. A surveillance ML-driven tool receives historical information and learns to recognize acceptable and appropriate transactional patterns and then have the ability to identify transactions that do not “fit” that pattern, falling outside of the normal flow of business, and may be anomalous, such as ill-timed or duplicative payments, falsified invoices, and other suspicious transactions.

Integration with predictive analytics

Another approach to detecting suspicious transactions involves integration with predictive analytics. Predictive algorithms can be employed to analyze historical data and automatically create predictive rules to complement those that have been manually created.

One of the recent examples of using predictive analytics to fight corruption is the early warning system based on a neural network approach developed by the team of the Higher School of Economics and University of Valladolid. The solution relied on self-organizing maps (SOMs), a kind of artificial neural network that aims to mimic brain functions. The team looked at data from actual cases of corruption cases in Spain, using the neural network to look at the probability of corruption cases in different time scenarios, showing that economic factors, particularly taxation of real estate, economic growth, increased house prices, and the growing number of deposit institutions and non-financial firms may induce public corruption.

All these techniques help make investigations more efficient — and cost effective. One of the key factors of increased use of AI-driven solutions to fight fraud and corruption is that clients are getting more comfortable with data, techniques to analyze data and Artificial Intelligence in general. However, it is paramount to remember that each situation is dynamic and iterative. It is recommended to run different techniques as a way to cross reference. This will help to examine larger amounts of data at a higher and more efficient rate.

[latinbossboy9]

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Public Corruption



Public corruption, the FBI’s top criminal investigative priority, poses a fundamental threat to our national security and way of life. It can affect everything from how well our borders are secured and our neighborhoods protected to how verdicts are handed down in courts to how public infrastructure such as roads and schools are built. It also takes a significant toll on the public’s pocketbooks by siphoning off tax dollars—it is estimated that public corruption costs the U.S. government and the public billions of dollars each year. The FBI is uniquely situated to combat corruption, with the skills and capabilities to run complex undercover operations and surveillance.

Overview 

The Bureau’s Public Corruption program focuses on:

Investigating violations of federal law by public officials at the federal, state, and local levels of government;

Overseeing the nationwide investigation of allegations of fraud related to federal government procurement, contracts, and federally funded programs;

Combating the threat of public corruption along the nation’s borders and points of entry in order to decrease the country’s vulnerability to drug and weapons trafficking, alien smuggling, espionage, and terrorism.

Addressing environmental crime, election fraud, and matters concerning the federal government procurement, contracts, and federally funded programs.

In 2022, the FBI created the International Corruption Unit (ICU) to oversee the increasing number of investigations involving global fraud against the U.S. government and the corruption of federal public officials outside of the continental U.S. involving U.S. funds, persons, businesses, etc. The ICU’s tasks include:

Overseeing the Bureau’s Foreign Corrupt Practices Act (FCPA) and antitrust cases;

Maintaining operational oversight of several International Contract Corruption Task Forces, which investigate and prosecute individuals and firms engaged in bribery, illegal gratuities, contract extortion, bid rigging, collusion, conflicts of interest, product substitution, items and/or services invoiced without delivery, theft, diversion of goods, and individual and corporate conspiracies on every level of U.S. government operations.

No other law enforcement agency has attained the kind of success the FBI has achieved in combating corruption. This success is due largely to the cooperation and coordination from a number of federal, state, local, and tribal law enforcement agencies to combat public corruption. These partnerships include, but are not limited to the Department of Justice, Agency Offices of Inspector General; law enforcement agencies’ internal affairs divisions; federal, state and local law enforcement and regulatory investigative agencies; and state and county prosecutor’s offices.





Types of Corruption 

Prison Corruption

The FBI’s prison corruption initiative, which began in June 2021, addresses contraband smuggling by local, state, and federal prison officials in exchange for bribe payments. Through this initiative, the Bureau works to develop and strengthen collaborative relationships with state/local corrections departments and the U.S. Department of Justice Office of Inspector General to help identify prison facilities plagued with systemic corruption and employ appropriate criminal investigative techniques to combat the threat. Prison officials and staff being co-opted, even if unwittingly, betrays the public trust, threatens the integrity of the justice system in the U.S., and threaten national security interests overall.

Schemes to corrupt prison officials come in a variety of forms, including:

Testing: An offer of simple items, like prison commissary goods, is made to prison officials. If accepted, the inmate confirms the official’s administrative misstep, then urges the official to smuggle contraband under threat of reporting the official’s misconduct.

Active recruiting: Civilian gang members with no prior criminal history are recruited by incarcerated gang members to apply to become correctional officers, with promises of additional income paid by the inmates’ criminal enterprise.

Empathy: Prison inmates study corrections personnel working in the facility and determine whether particular staff members are susceptible to exploitation. This ploy typically results in improper interpersonal relationships and the corrupted official’s integrity being compromised to the benefit of the inmate.

Border Corruption

The federal government is responsible for protecting approximately 7,000 miles along the U.S. border and 95,000 miles of U.S. shoreline, and every day, over a million people visit the U.S. and enter through one of the more than 300 official ports of entry into the U.S., as well as through seaports and international airports. The FBI recognizes the very real threat public corruption at our nation’s borders and all other ports of entry pose.

Common acts of border corruption involve drug trafficking and alien smuggling. Throughout the U.S., the FBI has investigated corrupt government and law enforcement officials who accept bribes and gratuities in return for allowing loads of drugs or aliens to pass through ports of entry or checkpoints; protecting and escorting loads of contraband; overlooking contraband; providing needed documents, such as immigration papers and driver’s licenses; leaking sensitive law enforcement information; and conducting unauthorized records checks.

Border corruption potentially impacts national security as well—corrupt officers might believe they are accepting a bribe simply in return for allowing a carload of illegal aliens to enter the U.S., when they might actually be facilitating the entry of a group of terrorists. Or a corrupt official who expedites immigration paperwork or helps obtain an identification document in return for a bribe or gratuity might actually be facilitating an operation of a terrorist cell, foreign counterintelligence network, or criminal enterprise.

Oftentimes the Bureau brings its expertise to bear on joint investigations with its partners in federal, state, and local law enforcement. Many of these investigations involve FBI border corruption task forces and working groups located in nearly two dozen cities along our borders. Members of these task forces and working groups stand shoulder to shoulder to combat corrupt officials, both operationally and through the sharing of intelligence and information, along with the use of trend analysis, lessons learned, and best practices.

Federally, the FBI coordinates investigative efforts along the borders with the Department of Homeland Security Office of Inspector General; Customs and Border Protection Internal Affairs; Transportation Security Administration; Drug Enforcement Administration; Bureau of Alcohol, Tobacco, Firearms, and Explosives; U.S. Immigration and Customs Enforcement-Office of Professional Responsibility.



Story

Corruption on the Border

The FBI—in collaboration with the Department of Homeland Security—is launching a campaign to raise awareness about the dangers of border corruption.

International Corruption 

The FBI’s International Corruption Unit (ICU) is the leading investigative entity in combating foreign corruption. ICU manages five programs:

Foreign Bribery/Foreign Corrupt Practices Act (FCPA)

Foreign Corruption/Kleptocracy Program

Antitrust

International Fraud Against the Government

International Corruption of Federal Public Officials

Foreign Corrupt Practices Act

ICU has management responsibility and program oversight for FBI investigations under the FCPA. The 1977 legislation has two main provisions. The first deals with bribery of foreign officials, and the second deals with accounting transparency requirements under the Securities Exchange Act. The dual elements were designed to facilitate parallel criminal and civil enforcement to stem corruption and promote fair business practices worldwide. The anti-bribery provision makes it illegal for U.S. companies and certain foreign companies to bribe foreign officials to obtain or retain business. The bribes can be in the form of money or any other items of value. The accounting provision of the FCPA focuses on the Securities Exchange Act requirements applying to all foreign companies whose securities are listed on the U.S. stock exchanges and U.S. companies.

The United States cannot charge the foreign official under the FCPA; rather, the United States works together with international law enforcement partners to investigate U.S. subjects who are complicit in paying bribes to foreign officials. The supply and demand equation of bribe paying and receiving illustrates the FCPA and kleptocracy violations as two sides of the same coin. For more information, see this detailed FCPA Resource Guide.

Kleptocracy

Kleptocracy, literally meaning "the rule by thieves," is a form of political corruption in which the ruling government seeks personal gain and status at the expense of the governed. Through graft and embezzlement of state funds, corrupt leaders amass tremendous wealth at the expense of the broader populace. Some of the most egregious examples have occurred in countries with very high rates of poverty. The inherent challenge for corrupt leaders is covertly expatriating and holding money in secure locations where it can be accessed in the future. Generally, that requires international movement of funds. When transfers occur in U.S. dollars or transit the U.S. banking system, federal money laundering jurisdiction is established. The FBI initiates money laundering investigations to trace the international movement of assets and, in conjunction with foreign partners, forfeit and repatriate assets back to legitimate authorities in victim countries.

Antitrust

ICU has program management responsibility for the FBI’s antitrust investigations, both domestic and international, which target conspiracies among competitors to fix prices, rig bids, or allocate markets or customers. These conspiracies deprive U.S. consumers of true competition, an economic bedrock of our free and democratic society. Perpetrators often operate in multinational companies that bask in illegal profits at the expense of U.S. consumers. Stolen by cartels, the ill-gotten gains and competitive advantages reduce supply, eliminate incentives to compete by offering better and more innovative products and services, and destabilize economic markets.

International Contract Corruption

ICU has program management responsibility over cases involving international fraud against the government and international corruption of federal public officials. The FBI was a co-founder of the International Contract Corruption Task Force, which was created in 2019 with the goal of addressing contract fraud concerns. These concerns stemmed from overseas U.S. government spending during the wars in Afghanistan and Iraq. These cases typically involve bribery, gratuities, contract extortion, bid rigging, collusion, conflicts of interest, product substitution, items/services invoiced without delivery, diversion of goods, and corporate and individual conspiracies at various levels of U.S. government operations.

ICU’s program extends beyond the war effort to include worldwide contingency operations involving U.S. military actions, foreign aid and development, and humanitarian aid in any international region. Spending on these programs is highly susceptible to corruption and fraud by those wishing to take advantage of the chaotic circumstances surrounding these benevolent endeavors. Misuse of U.S. funds overseas poses a threat to the United States and other countries by promoting corruption within the host nation, damaging diplomatic relations, inadvertently supporting insurgent activity, and potentially strengthening criminal and terrorist organizations.

International Anti-Corruption Coordination Centre

The FBI works with multiple law enforcement partners from around the world as part of the International Anti-Corruption Coordination Centre (IACCC). Established in 2017, the IACCC is a coordinated and collaborative effort to provide information, assistance and other support to agencies investigating public corruption offenses.

IACCC Participants

Australia: Australian Federal Police

Canada: Royal Canadian Mounted Police

Interpol

New Zealand: Serious Fraud Office, New Zealand Police

Singapore: Corrupt Practices Investigation Bureau

United Kingdom: National Crime Agency

United States: FBI, DHS (ICE, HSI)

Learn More

IACCC Brochure (pdf)

ICU Initiatives 

ICU oversees two large initiatives: the program management of four international corruption squads dedicated to investigating FCPA, kleptocracy, and antitrust cases and the development of a robust private sector outreach program.

International Corruption Squads

The international corruption squads (ICS), based in Los Angeles, Miami, New York City, and Washington, D.C., were created to address the national impact of foreign bribery, kleptocracy, and antitrust schemes. These schemes negatively affect U.S. financial markets and economic growth when inadequately addressed. They are unique in nature in that they are international matters with the overt criminal acts typically occurring outside U.S. borders.  Without these dedicated resources, it was difficult for FBI divisions to investigate international matters that did not directly affect their area of responsibility as clearly as other violations; therefore, the FBI created four international corruption squads to enable a focus on international corruption matters without draining resources from the field.

The ICS are a vital resource to combat international cartels and corruption. The violations addressed by the ICS are equally recognized by both DOJ and the FBI as risks to U.S. national interests. These squads not only lend additional resources to a global threat, but they also allow the FBI to attack the matters and use sophisticated investigative techniques that have long been successfully utilized by the FBI to address complex criminal matters.

Private Sector Outreach 

In an effort to combat international corruption and cartels, the FBI’s ICU created a proactive strategy that places an emphasis on strengthening existing relationships and forging new partnerships in the private sector. This is not new to the FBI. We have leveraged relationships throughout our 100+ years of investigations—from fighting organized crime to combating terrorism. Nonetheless, we believe by fostering these vital relationships, the FBI will be able to effectively fight international corruption to ensure a fair and competitive global market environment for companies resulting in a strong U.S. economy. 

Public Corruption News 

04.05.2022 — Former Correctional Officer Sentenced for Smuggling Cell Phones Into Dauphin County Prison

04.01.2022 — Former Deputy Sheriff Convicted of Drug Trafficking

03.31.2022 — Former Coal Company Vice President Arrested and Charged with Foreign Bribery, Money Laundering, and Wire Fraud

03.31.2022 — NHA Director of Information Technology Admits Embezzling Funds to Purchase Thousands of Electronic Devices

03.31.2022 — Former Puerto Rico Legislator and Two Capitol Employees Plead Guilty to Bribery and Kickback Scheme

03.31.2022 — Springfield Health Care Charity Pays More Than $8 Million Related to Federal Embezzlement, Bribery Investigation

03.29.2022 — Kennewick Man Pleads Guilty to Conspiracy to Obstruct an Official Proceeding

03.29.2022 — Former Lawrence County Attorney Pleads Guilty to Wire Fraud and Federal Program Theft

More News



Regional Corruption Hotlines

Local FBI phone number hotlines for reporting corruption.



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[bryncarson-blog]

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[nox-lathiaen]

Attorney - Senior Counsel - Healthcare Law - Woodbridge, NJ

Apply legal expertise in healthcare law, including FDA regulatory proficiency and commercial contract experience to advise clients of a North East USA Multi-Office Regional Law Firm. Serve as legal counsel to various clients, advising on structuring and negotiating agreements, dispute resolution, and legal strategy impacting business decisions. Advise clients to promote compliance with industry standards of conduct and ethics, including fraud and abuse, anti-bribery, ant-kickback, and Foreign Corrupt Practices Act (FCPA). Provide advice to clients on legal risks of key business decisions that support strategic initiatives. Negotiate and draft complex commercial contracts and other commercial agreements. Manage prosecution and defense of legal claims, including managing the process and working with clients to ensure efficient and effective outcomes. Receive competitive starting compensation with full medical, dental and vision benefits along with matched 401(k) and performance bonus. Paid time off for personal days, vacations and holidays. Tuition reimbursement for continued education and paid training provided. For complete details contact Greg Foss at: (609) 584-9000 ext 270 Or submit resume online at: dmc9.com/gbf/app.asp Or email to: 1000043988_10006796 AT najbcareers302.com Please reference #39406112 when responding. Education Requirements: Doctorate degree Minimum Experience Requirements: 5-10 years Job City Location: Woodbridge Job State Location: NJ Job Country Location: USA Salary Range: $250,000to $350,000 Diedre Moire Corporation, Inc. Diedremoire_dot_com WE ARE AN EQUAL OPPORTUNITY EMPLOYER and our employment decisions are made without regard to race, color, religion, age, sex, national origin, handicap, disability or marital status. We reasonably accommodate individuals with handicaps, disabilities and bona fide religious beliefs. Jobs Career Position Hiring. CONSIDERED EXPERIENCE INCLUDES: Attorney Counsel Lawyer Healthcare Compliance Regulatory Compliance Healthcare Law #DiedreMoire #AttorneyJobs #JobSearch #JobHunt #JobOpening #Hiring #Job #Jobs #Careers #Employment #jobposting DISCLAIMER: We will make every effort to consider applications for all available positions and shall use one or more of the contact methods and addresses indicated in resume or online application. Indicated location may be proximate or may be desirable point of embarkation for paid or unpaid relocation to another venue. Job descriptions may fit single or multiple presently available or anticipated positions and are NOT an offer of employment or contract implied or otherwise. Described compensation is not definite nor precise and may be estimated and approximate and is negotiable depending on market conditions and candidate availability and other factors and is solely at the discretion of employers. Linguistics used herein may use First Person Singular and First Person Plural grammatical person construction for and with the meaning of Third Person Singular and Third Person Plural references. We reserves the right to amend and change responsibilities to meet business and organizational needs as necessary. Response to a specific posting or advertisement may result in consideration for other opportunities and not necessarily the incentive or basis of the response. Nothing herein is or may be considered a promise, guarantee, offer, pledge, agreement, contract, or oath. If you submit an application or resume which contains your email address, we will use that email address to communicate with you about this and other positions. We use an email quality control service to maintain security and a remove and dead address filter. To cancel receiving email communications, simply send an email from your address with the word "remove" in the subject line to pleaseremove_AT_candseek4.com Or, visit the website at jobbankremove_dot_com. If you have further concern regarding email received from us, call (609) 584-5499. Reference : Attorney - Senior Counsel - Healthcare Law - Woodbridge, NJ jobs Source: http://jobrealtime.com/jobs/technology/attorney-senior-counsel-healthcare-law-woodbridge-nj_i9568

[jobsaggregation2]

Attorney - Senior Counsel - Healthcare Law - Woodbridge, NJ

Apply legal expertise in healthcare law, including FDA regulatory proficiency and commercial contract experience to advise clients of a North East USA Multi-Office Regional Law Firm. Serve as legal counsel to various clients, advising on structuring and negotiating agreements, dispute resolution, and legal strategy impacting business decisions. Advise clients to promote compliance with industry standards of conduct and ethics, including fraud and abuse, anti-bribery, ant-kickback, and Foreign Corrupt Practices Act (FCPA). Provide advice to clients on legal risks of key business decisions that support strategic initiatives. Negotiate and draft complex commercial contracts and other commercial agreements. Manage prosecution and defense of legal claims, including managing the process and working with clients to ensure efficient and effective outcomes. Receive competitive starting compensation with full medical, dental and vision benefits along with matched 401(k) and performance bonus. Paid time off for personal days, vacations and holidays. Tuition reimbursement for continued education and paid training provided. For complete details contact Greg Foss at: (609) 584-9000 ext 270 Or submit resume online at: dmc9.com/gbf/app.asp Or email to: 1000043988_10006796 AT najbcareers302.com Please reference #39406112 when responding. Education Requirements: Doctorate degree Minimum Experience Requirements: 5-10 years Job City Location: Woodbridge Job State Location: NJ Job Country Location: USA Salary Range: $250,000to $350,000 Diedre Moire Corporation, Inc. Diedremoire_dot_com WE ARE AN EQUAL OPPORTUNITY EMPLOYER and our employment decisions are made without regard to race, color, religion, age, sex, national origin, handicap, disability or marital status. We reasonably accommodate individuals with handicaps, disabilities and bona fide religious beliefs. Jobs Career Position Hiring. CONSIDERED EXPERIENCE INCLUDES: Attorney Counsel Lawyer Healthcare Compliance Regulatory Compliance Healthcare Law #DiedreMoire #AttorneyJobs #JobSearch #JobHunt #JobOpening #Hiring #Job #Jobs #Careers #Employment #jobposting DISCLAIMER: We will make every effort to consider applications for all available positions and shall use one or more of the contact methods and addresses indicated in resume or online application. Indicated location may be proximate or may be desirable point of embarkation for paid or unpaid relocation to another venue. Job descriptions may fit single or multiple presently available or anticipated positions and are NOT an offer of employment or contract implied or otherwise. Described compensation is not definite nor precise and may be estimated and approximate and is negotiable depending on market conditions and candidate availability and other factors and is solely at the discretion of employers. Linguistics used herein may use First Person Singular and First Person Plural grammatical person construction for and with the meaning of Third Person Singular and Third Person Plural references. We reserves the right to amend and change responsibilities to meet business and organizational needs as necessary. Response to a specific posting or advertisement may result in consideration for other opportunities and not necessarily the incentive or basis of the response. Nothing herein is or may be considered a promise, guarantee, offer, pledge, agreement, contract, or oath. If you submit an application or resume which contains your email address, we will use that email address to communicate with you about this and other positions. We use an email quality control service to maintain security and a remove and dead address filter. To cancel receiving email communications, simply send an email from your address with the word "remove" in the subject line to pleaseremove_AT_candseek4.com Or, visit the website at jobbankremove_dot_com. If you have further concern regarding email received from us, call (609) 584-5499. Reference : Attorney - Senior Counsel - Healthcare Law - Woodbridge, NJ jobs from Latest listings added - JobsAggregation http://jobsaggregation.com/jobs/technology/attorney-senior-counsel-healthcare-law-woodbridge-nj_i8896

[toldnews-blog]

New Post has been published on https://toldnews.com/world/jailed-french-executive-who-felt-force-of-us-bribery-law/

Jailed French executive who felt force of US bribery law

Image copyright Brigitte Baudresson

Image caption Pierucci’s five-year ordeal is a cautionary tale for globe-trotting executives

In April 2013, as Frédéric Pierucci stepped off a plane at New York’s JFK airport during a routine business trip, he was seized and handcuffed by uniformed men.

The 45-year-old executive for Alstom, a French energy and transport group, was then driven to the FBI building in Manhattan, where the reason for his arrest became clear.

In 2003-4, a federal prosecutor explained, Pierucci had authorised bribes to Indonesian officials to secure a contract for boilers at a power plant.

This was true. At the time, he was working for an Alstom subsidiary in Connecticut. Bribery was common practice at the company then.

Risky business

Pierucci had assumed he was safe from prosecution because he had not arranged the Indonesian kickbacks, only signed off on them. And since then, Alstom had assured the US justice department that it was cleaning up its act.

But, as Pierucci discovered, the department had been gathering evidence against him on charges including wire fraud and money laundering.

He did not know about them because the indictment had remained sealed – as it was for Meng Wanzhou, the Huawei executive who was arrested in Canada last year and denies US allegations that she helped evade sanctions on Iran.

Pierucci was to spend more than five years in the clutches of the American justice system. His story illustrates the risks faced by foreign businessmen who – sometimes unbeknownst to them – are accused of breaching US law.

Image copyright Google

Image caption The bribes were in connection with the Tarahan power plant on Sumatra island, which was completed in 2007

The US government has long been dead serious about corruption. In 1977 it approved the Foreign Corrupt Practices Act (FCPA), the world’s first ban on bribing foreign officials. Elsewhere, companies continued to get away with it for decades. In the 2000s, however, spurred by a campaign by the OECD, other developed nations began to clamp down.

Co-operation from foreign law-enforcement agencies helped the US government export its anti-corruption drive. Alstom is a case in point. The justice department pursued the company after Italian, Swiss and British prosecutors had exposed the company’s global bribery scheme.

American investigators have their own way of pursuing white-collar crime. Instead of launching raids on company offices, they start by asking for co-operation. The request is polite but the underlying message brutal: help us incriminate yourself and we will not come down as hard as we might otherwise.

Prison rules

When Alstom was first approached in this way in 2011, its then-chief lawyer Fred Einbinder understood the need for coming clean. “When you get a subpoena, it’s not like you’ve got a choice,” he tells the BBC.

But his advice to co-operate was ignored. Later that year, Einbinder was let go.

Image copyright Reuters

The prosecutor offered his quarry a deal: Pierucci could be released if he agreed to act as a secret FBI informant within Alstom. He declined the offer.

The next day, Pierucci was denied bail and transferred to the Wyatt Detention Facility, a high-security prison in Rhode Island.

He had to adjust quickly to living alongside hardened criminals. “You must not look fellow inmates in the eye. You must not touch or even brush past them. Any perceived slight can turn into a fight,” Pierucci told the BBC in a recent interview. A 70-year old man was raped by a drugged-up youth in a nearby cell, he says.

Detention conditions were not Pierucci’s only, or even main, concern. He had no idea how long he would stay inside. The Connecticut-based lawyer appointed and paid by Alstom to defend him said his best hope for release was to plead guilty in a deal with prosecutors.

‘Monumental error‘

The advice may have been sound, but there was a problem. Pierucci wanted to argue that he was far down the chain of command. However he soon realised that the Alstom management would never go along with a line of defence that implicated them.

“At first I was happy that Alstom took charge of my defence – it was only later that I saw it had been a monumental error,” Pierucci says.

As months went by, the news got worse. Three other Alstom executives were arrested on bribery charges. If one of them struck a plea deal first, Pierucci’s own bargaining position would be undermined. He was in a race with the other defendants to satisfy the prosecutors.

Image copyright Google

Unsure about the next step, Pierucci turned to his cellmates for legal advice. Jacky, a veteran of the French Connection drug ring who had 36 years’ experience of the US penal system, warned him against accepting an “open plea”, where defendants sign away their presumed innocence without any guarantee on a sentence.

What Pierucci wanted, Jacky said, was a “binding plea” that commits prosecutors to a specific jail term. When he relayed this request to his lawyer, he was told – correctly – that open pleas were the only option in Connecticut.

But the lawyer thought he had a gentleman’s agreement with the prosecutor on a six-month sentence: if Pierucci admitted sole guilt, he could expect to be free by October. The alternative was to go to trial and risk up to 125 years in jail.

The pressure he was experiencing was far from unique. Thanks to mandatory sentences, US prosecutors wield huge powers. One of Pierucci’s fellow detainees, who had been caught with drugs but had no previous convictions, hanged himself in his cell after being offered 15 years as an opening bid.

Fired

In July 2013, hoping for release within months, Pierucci bowed to the inevitable and pleaded guilty. The plea deal, however, brought little relief.

Now that Pierucci was a convicted criminal, Alstom cut him loose. His absence, the dismissal letter read, “imperils the operation of the entity which you lead” and makes it impossible “to maintain our contractual relation”. In addition, it noted, his misdeeds “run counter to the values and the ethics of the group”.

Besides being apparently fired for not turning up for work while in jail, Pierucci found it a bit rich to be lectured about integrity by a firm that had engaged in corruption in many countries and been blacklisted over these practices by the World Bank.

But he recognises that the company had little choice. It made sense for Pierucci’s bosses to blame him as much as they could.

Image copyright Getty Images

Image caption As Alstom boss, Patrick Kron (right) was close to then-President Nicolas Sarkozy

Meanwhile Pierucci’s detention showed no sign of ending. October came and went. Six months turned into a year, without any news on sentencing. In a book on the case, Le Piège américain (the American trap), he compares his ordeal to being stuck in “an endless tunnel with slippery walls – nothing to hold on to.”

In June 2014, Pierucci was released after friends put up their homes as bond and later that year went home to Paris. But he was yet to be sentenced, and the possibility of more jail time still hung over him.

The uncertainty lasted another three years. In September 2017 Pierucci flew back to Connecticut for sentencing. The judge gave him 30 months.

He did not become a free man until late 2018, when he walked out of the Pittsburgh prison where he had served the second half of his sentence.

Paranoia?

Pierucci believes he was a pawn in three larger battles with global economic and political ramifications.

The first is the fight between the US justice department and Alstom, which resulted in total surrender by the French company.

In late 2014, it admitted having paid $75m bribes over a decade, in a scheme described by prosecutors as “astounding in its breadth, its brazenness and its worldwide consequences”. Alstom settled the case for $770m (£580m; €670m) – the largest-ever FCPA fine imposed by the department.

The arrests of Pierucci and other managers were crucial in breaking Alstom’s resistance. As then-Assistant Attorney General Leslie Caldwell said: “It was only after the department publicly charged several Alstom executives – three years after the investigation began – that the company finally co-operated.”

The second battle that Pierucci believes influenced his fate was the purchase of most of Alstom by its US rival General Electric (GE).

Image copyright Getty Images

Image caption Under CEO Jeffrey Immelt, GE made several mega deals, including GE’s acquisition of Alstom’s power business

The business saga and the legal cases unfolded in lockstep. Alstom boss Patrick Kron announced plans to sell the power business – 75% of the company – in mid-2014, when it was clear that the company was in the justice department’s crosshairs.

Shareholders approved the sale to GE that December. Three days later, the settlement in the bribery case took Alstom’s top brass off the hook.

Pierucci is among many in France who claim that the justice department was helping GE by keeping the pressure on Alstom until the sale was complete. According to a French parliamentary report published last year, the threat of a huge fine “undoubtedly… precipitated Mr Kron’s decision”.

Kron has always vehemently denied the allegation. “We absolutely did not make this transaction in response to any direct pressure on myself or anyone else,” he told MPs. Alstom’s power operations, he insists, were sold for the best business reasons. Indeed the purchase is widely seen as a costly mistake by GE, and in 2017 its CEO admitted as much.

The US justice department’s anti-corruption chief, Daniel Kahn, also rejects any suggestion of collusion. “We certainly didn’t force Alstom to plead guilty in order to help out GE. That never entered into consideration,” he told the BBC.

Image copyright Getty Images

Image caption Since the sale to GE, Alstom and its boss Henri Poupart-Lafarge have refocused on its transport business

Neither is the timing necessarily suspicious. The justice department could have taken the sale into account in its settlement with Alstom simply because of GE’s strong anti-corruption record. “In general, we don’t want to discourage companies with strong compliance programs from acquiring companies with weaker ones,” Kahn says.

Andrew Spalding, who teaches anti-corruption law at the University of Richmond, Virginia, notes that for any conspiracy between prosecutors and GE to work, it would also have to involve America’s independent judiciary. “That’s paranoia,” he says.

Power games

The third battle Pierucci is convinced he was dragged into is the biggest of all. It is nothing less than a struggle for worldwide supremacy.

In the subtitle of his book, he describes himself as a “hostage in the greatest campaign of economic destabilisation”. He is not alone in believing America is seeking to weaken foreign companies. This is the way most French analysts and many politicians have described the various Alstom sagas over the years.

Pierre Laporte, a former GE lawyer who now works as Pierucci’s partner, notes that 70% of firms targeted for US anti-bribery action are foreign – notably European. The FCPA and other laws that apply beyond US borders, Laporte says, are “tools of economic domination”.

Such suspicions may sound overblown, but they reflect serious concerns in France. Alstom, whose turbines power the country’s nuclear stations and submarines, is regarded as a strategic asset. Many worry that if a serious diplomatic spat arose with the US, as was the case during the Iraq war, French sovereignty could be undermined.

Image copyright Getty Images

Image caption A US company now makes the turbines that power French nuclear submarines

America’s judicial expansionism is a matter of concern for many countries whose companies are being pursued for doing business with Iran and other states targeted by American sanctions.

Since his return to Paris, however, Pierucci has focused on the narrow issue of the fight against corruption rather than geopolitical power games.

He and Laporte have set up a consultancy to help companies stay on the right side of anti-bribery prosecutors.

There is a big demand for Pierucci’s expertise. In 2016, France belatedly passed tough anti-corruption legislation and is enforcing it. The US justice department’s Daniel Kahn says he has a “very strong relationship” with his French counterparts – this recently resulted in a successful joint action against French bank Société Générale over bribes in Libya.

“Once you identify possible violations, you can put safeguards in place,” Pierucci says. He tells his clients to be particularly vigilant about hidden practices by overseas partners or consultants that may put them at risk.

Danger can lurk in unexpected places. In 2017 a retired Siemens manager was arrested while on holiday in Croatia and extradited to the US, where he was eventually convicted over bribes paid by the German group in Argentina in the 1990s.

As the reach of US legislation expands, foreign executives who fight the law may well find that the law wins.

[bonjourmoncher]

Hamilton Lindley Waco Business Leader at Neighborly Brands, a Compliance Officer Profile

A consistence official ought to force rules with a tone of sympathy. The best outcomes happen when a consistence official talks delicately, tunes in without interference, and talks gruffly. Be that as it may, it is important that the dull talk isn't rough. Individuals don't listen when they feel unjustifiably censured. Hamilton Lindley, a consistence administrator at Neighborly Brands has a one of a kind way to deal with be a consistence official.

While talking obtusely, advise individuals your goal is to instruct them. "Tell the individual that 'I'm not condemning. I'm teaching.' when depicting an approach to improve." Hamilton Lindley says.

Hamilton Lindleysuggests that graciousness goes far. "Everybody wants to be heard. Furthermore, despite the fact that it might be difficult to hear, they merit it." Hamilton Lindley says. Through his time with the world's biggest home administration franchisor, Hamilton Lindley has made extraordinary outcomes by talking delicately and conveying a major stick. "Abraham Lincoln said that the needed to be iron enveloped by velvet. That is my way to deal with these troublesome discussions." Says Hamilton Lindley.

Hamilton Lindley contemplated worldwide business law while his companions were playing kickball. Quick forward to today, and he has composed more emphatic letters than you've eaten cuts of pizza. He appreciates making convoluted things straightforward. Furthermore, he knowsthat calls merit an arrival that day. Hamilton Lindley methodologies worries as a down to business colleague. Not from an ivory tower.

Following 10 years in Dallas, Hamilton Lindley moved his group of five to the home of the Baylor Bears in Waco, Texas. Hamilton Lindley understood the mentally programming of his little girl was finished after she accepted that the Baylor Bear mascots rest simply in the wake of "eating all them Longhorns." If you want to see an excessive number of photographs of his family, you can discover Hamilton Lindley on Facebook Hamilton Lindleyand Hamilton Lindley Twitter and Hamilton Lindley Instagram.

While in Dallas, Hamilton Lindley was perceived as Best Lawyer in Dallas by D Magazine and President of the Dallas Federal Bar Association. Hamilton Lindley was named a Texas Super Lawyer from 2010-2016 and The National Trial Lawyers perceived Hamilton Lindley as a "Best 40 Under 40" legal counselor and a "Main 100 Trial Lawyer."

Hamilton Lindley has composed on numerous business the executives points and lawful themes.

The Secret of Perfect Timing

Despondency Kills by Silence

Selling is Human

To begin with, Break every one of the Rules

Start with Why

Make Stories Stick

The Formula of Success

Demonstrating Fraud on the Market

Hamilton Lindley is frequently referenced in the news, including the accompanying stories:

Waco Personal Injury Attorney Hamilton Lindley Receives Top Trial Lawyer Award

Lawyer Hamilton Lindley Names Among Best Lawyers in Dallas by D Magazine

Hamilton Lindley Files Lawsuit over Biker Gang Shootout

Scene Change for Twin Peaks Cases

Hamilton Lindley Quoted in Forbes Magazine about Foreign Corrupt Practices Act Compliance

Hamilton Lindley Baylor Law Alumni Association

Hamilton Lindley clarifies why pay off examinations flash investor claims

Hamilton Lindley chose as a Super Lawyer

Hamilton Lindley Baylor Law School

As Toyota Saga proceeds, investors prepared case driven by Hamilton Lindley

Hamilton Lindley cited in Huron embarrassment case

Hamilton Lindley on the Rocket Docket by Baylor Law School

Hamilton Lindley on the Cross and Crescent magazine

Hamilton Lindley on the Docket Call

Waco Personal Injury Attorney Hamilton Lindley Receives Top Trial Lawyer Award

Waco individual damage lawyer, Hamilton Lindley, has been named one of the Top 100 Trial Lawyers in Texas by The National Trial Lawyers Association. As a first time beneficiary of the honor Mr. Lindley is eager to have been chosen for such a high respect.

The National Trial Lawyers Top 100 touts itself as a welcome just association made out of the chief preliminary attorneys from each state in the country who meet stringent capabilities as common offended party or potentially criminal protection preliminary legal counselors. Choice depends on an intensive multi-stage process which incorporates peer designations joined with outsider research. Enrollment is stretched out exclusively to the chosen few of the most qualified lawyers from each state who show prevalent capabilities of authority, notoriety, impact, stature and open profile.

Every one of the recognized Top 100 individuals have the information, ability, experience and achievement held by just the best and best attorneys in America. By joining assets, power and impact, The National Trial Lawyers: Top 100 is dedicated to saving and ensuring equity for all.

Lawyer Hamilton Lindley Named Among Best Lawyers by D Magazine

The Dallas preliminary law office Deans and Lyons is satisfied to report that Hamilton Lindley has earned a spot on D Magazine's posting of "The Best Lawyers in Dallas." Mr. Lindley was perceived among Dallas' top legal counselors for his work in protections prosecution and authorization.

To accumulate the rundown of the city's top lawyers, D Magazine requested selections from 9,000 legal counselors and judges all through North Texas. Individual lawyers vote in favor of chosen one's that exhibit exclusive expectations as far as nature of work and honesty in the legitimate calling. The distribution's editors at that point worked with a blue-strip board of legal advisors to conclude the posting, which is highlighted in the May 2014 release of D Magazine, and will be accessible during the time at

Hamilton Lindley is routinely perceived among the top legal counselors in Texas. He has been highlighted in the Texas Super Lawyers posting of the state's top legal advisors since 2010.

"Speaking to the two offended parties and respondents in protections prosecution encourages me give one of a kind understanding to my customers," Hamilton Lindley said. "I am respected to be chosen by my friends for this posting in D Magazine."

'Licentious PART OF LAW'

Recently, enormous payouts to the central government have turned out to be progressively normal. Over the most recent two years, organizations have paid FCPA fines and ejections worth more than $2.6 billion, almost triple the estimation of settlements in the earlier four years, as per information assembled by law office Shearman and Sterling. In investor cases that please the impact points of a major FCPA settlement, juries are progressively disposed to be thoughtful to the offended parties, legal advisors state. Worry about huge potential decisions can trigger enormous settlements.

"Renumeration is a lustful piece of law. It's something that individuals can comprehend — and it gets them furious," said Hamilton Lindley, a partner at six-attorney Goldfarb Branham in Dallas, one of around two dozen firms that have recorded FCPA-related claims in the most recent year.

Offended parties' legal counselors are likewise attracted to these cases since organizations under government gift examination normally have just persevered through awful press and burned through millions on outside insight and globe-jogging measurable bookkeepers. Avon Products, for instance, burned through $48 million in the initial a half year of this current year on an interior examination started by a representative's case that organization staff made ill-advised installments to Chinese authorities. After the organization uncovered the claims to the Justice Department and Securities and Exchange Commission, which opened examinations, three investor suits were recorded in U.S. Area Court for the Southern District of New York. An Avon representative declined to remark on the examinations or the private case.

In Huron outrage, shadows of Arthur Andersen

Lawyer Hamilton Lindley of the Kendall Law Group, a Dallas-based law office, said he expected a class-activity protest to be documented for the benefit of investors this week.

"It's normal to investigate whether the way of life of Arthur Andersen seeped over into the way of life of Huron Consulting," Lindley said. "That is an inquiry we will seek after in our examination."

The unintended results of the Justice Department's FCPA arrangement essentially keep on mounting. The extreme criminalization by U.S. government attorneys of conduct that ought to never be approved, however is all inclusive efficient, has created numerous results. Meet one of them: Hamilton Lindley, an expert protections class-activity legal advisor. Over the most recent couple of months he has pursued corporate exposures of FCPA examinations by suing the sheets of chiefs of Weatherford International, Parker Drilling, Avon Products and Pride International. Lindley is presently investing a fourth of his energy in the FCPA and is very genuine in saying he is simply following the lead of the Department of Justice and the Securities and Exchange Commission.

"I think the way that these organizations have been submitting unite abroad honestly is an intriguing point for juries to hear," Lindley let me know. "It's the new authorization system of the DOJ and SEC so private practice attorneys are keen on what government legal counselors are doing."

In the claim Lindley documented against Weatherford and its board, for instance, Lindley has made sense of by taking a couple of minutes to peruse a SEC recording that the "Weatherford Board has caused an astounding $108 million in expenses and costs regarding FCPA-related examinations," which does exclude the "monetary punishment that Weatherford is probably going to need to pay to determine the DOJ and SEC examinations." So the general thought is for Lindley and his firm, Goldfarb Branham, to likewise make some cash off of Weatherford's lead.

Offended party's Lawyers Join the Bribery Racket

The unintended results of the Justice Department's FCPA approach basically keep on mounting. The serious criminalization by U.S. government attorneys of conduct that ought to never be approved, however is universally deliberate, has delivered numerous results. Meet one of them: Hamilton Lindley, an expert protections class-activity attorney. Over the most recent couple of months he has

[jobswzayef]

Compliance Counsel

Compliance Counsel

The Compliance Counsel Middle East role the Role leads and implement’s Nokia’s compliance program in Middle East and neighbouring countries including Egypt. The Role reports to the Lead Compliance Counsel Middle East and Africa Market MEA . The Role requires strong working relationships with leaders in the business and functions Legal Compliance Finance HR Procurement and others in the Middle East and Egypt. The Role also requires extensive collaboration and coordination with other members of the global Ethics Compliance team. The Role is responsible for the implementation of the compliance program and plan aligned to the Market and global compliance programs and strategies. The Role is accountable for promoting and monitoring world class compliance practices and to embed a culture of ethics and integrity throughout the territory as follows Major Responsibilities

Deploy Nokia’s global compliance program throughout the perimeter by ensuring that E C global policies processes and tools are effectively communicated to the appropriate employee groups

Conduct and support compliance risk assessments

Design and implement localized compliance programs in individual countries and entities as needed and in accordance with the priorities and direction set by the Lead Compliance Counsel for Middle East and Africa

Conduct periodic bi annually Regional Compliance Committees with senior Market Unit management teams to drive management understanding and accountability of compliance risks

Support Lead Compliance Counsel MEA with the MEA Market or other Market Unit Regional Compliance Committees as needed

Gather synthesize and report key compliance data to business leaders and the Lead Compliance Counsel for Middle East and Africa

Collaborate with HR Finance Procurement and other subject matter focused “2nd line” functions” on program design implementation and support

Be a Trusted Business Partner deliver effective compliance counsel and advice to leaders and employees a across Middle East. Act as the primary contact point and internal expert with respect to matters including those involving or requiring engagement with external authorities

Build strong effective relationships with key business functional and E C leaders and employees to drive awareness and accountability for compliance issues and impacts and ownership and support for compliance programs

Network with compliance and business professionals outside Nokia in the region and beyond to drive Nokia’s goal of Competitive Distinction Through Integrity

Conduct and or cascade targeted training on compliance related topics latest policies and or procedures to high risk managers and employees

Promote and support a robust open reporting culture including by supporting the Ombuds program and personnel within the perimeter

Identify compliance matters that require follow up or investigation and as appropriate conduct or support investigations in conjunction with the Business Integrity Group Nokia’s investigations team or otherwise refer issues to the appropriate internal investigating body

Convene and lead the disciplinary processes in appropriate cases involving substantiated Ethics Compliance violations. Adapt and support the global framework as appropriate where needed due to local labour laws

Monitor the installation and effectiveness of compliance controls and programs in Middle East including Compliance Control Frameworks reviews risk assessment analysis review of internal audit findings and other monitoring activities. Develop and lead remediation activities as needed

Drive a culture of integrity compliance and accountability from the top leaders in the organization through to all employees

Support compliance due diligence and approvals activities e.g. third party screening gifts hospitality approvals sponsorships donations approvals as needed

Minimum Requirements

Language Strong written and verbal skills in English

Minimum professional experience of 10 years with 5 years of relevant compliance experience.

Experience and understanding of compliance issues confronting the industry.

Strong knowledge of key anti bribery legislation including the FCPA UK Bribery Act and other applicable national and international legislation.

Experience conducting analysing and or making decisions and recommendations based on compliance due diligence. Preferred Background

Has worked in or provide relevant advisory services to multinational companies with a matrix organization.

Professional certification or qualification in Law Accounting and or Audit.

Masters level academic degree from recognized University in Law or Accounting.

Legal experience preferred including

Work in a prosecutor or regulatory agency office with jurisdiction over corporate criminal regulatory matters.

Relevant work in an in house legal department or at a major international or regional law firm representing corporate clients in investigative criminal or regulatory matters.

Relevant accounting and audit experience in house or external including work designing auditing and implementing anti fraud corruption money laundering controls.

Experience conducting and leading internal investigations

Experience conducing disciplinary committees or panels or otherwise supporting disciplinary processes

Experience writing and deploying compliance policies and or Codes of Conduct

Experience designing deploying analysing and or using compliance risk assessments.

Proven project management skills Strong commercial experience and skill set Competencies

Strong written and verbal communication skills clear communicator who can write and speak simply effectively and persuasively.

Able to operate effectively in complex organisational and regulatory environments

Demonstrated ability to partner effectively with others in addressing complex issues

Able to work independently including ability to identify and select own priorities plan and execute.

Adept at solving complex business critical problems in a calm manner and with sound business judgment.

Strong networker internally and externally.

Able to work well with ambiguity

A team player with a strong ethos of collegiality and mutual respect.

* راتب مجزي جداً. * مكافأت و حوافز متنوعة. * توفير سكن مؤثث أو بدل سكن. * أنتقالات أو توفير بدل عنها. * توفير تذاكر السفر لمن يشغل الوظيفة و عائلته. * نسبة من الأرباح الربع سنوية. * أجازات سنوية مدفوعة الراتب بالكامل. * مسار وظيفي واضح للترقيات. * بيئة عمل محفزة و مناسبة لحالة الموظف. * تأمين طبي للموظيف و عائلته. * تأمينات أجتماعية. التقدم و التواصل مباشرة دون و سطاء عند توافر الألتزام و الجدية التامة و المؤهلات المطلوبة علي: jobswzayef@gmail.com

[cvwing1]

Attorney - Senior Counsel - Healthcare Law - Woodbridge, NJ

Apply legal expertise in healthcare law, including FDA regulatory proficiency and commercial contract experience to advise clients of a North East USA Multi-Office Regional Law Firm. Serve as legal counsel to various clients, advising on structuring and negotiating agreements, dispute resolution, and legal strategy impacting business decisions. Advise clients to promote compliance with industry standards of conduct and ethics, including fraud and abuse, anti-bribery, ant-kickback, and Foreign Corrupt Practices Act (FCPA). Provide advice to clients on legal risks of key business decisions that support strategic initiatives. Negotiate and draft complex commercial contracts and other commercial agreements. Manage prosecution and defense of legal claims, including managing the process and working with clients to ensure efficient and effective outcomes. Receive competitive starting compensation with full medical, dental and vision benefits along with matched 401(k) and performance bonus. Paid time off for personal days, vacations and holidays. Tuition reimbursement for continued education and paid training provided. For complete details contact Greg Foss at: (609) 584-9000 ext 270 Or submit resume online at: dmc9.com/gbf/app.asp Or email to: 1000043988_10006796 AT najbcareers302.com Please reference #39406112 when responding. Education Requirements: Doctorate degree Minimum Experience Requirements: 5-10 years Job City Location: Woodbridge Job State Location: NJ Job Country Location: USA Salary Range: $250,000to $350,000 Diedre Moire Corporation, Inc. Diedremoire_dot_com WE ARE AN EQUAL OPPORTUNITY EMPLOYER and our employment decisions are made without regard to race, color, religion, age, sex, national origin, handicap, disability or marital status. We reasonably accommodate individuals with handicaps, disabilities and bona fide religious beliefs. Jobs Career Position Hiring. CONSIDERED EXPERIENCE INCLUDES: Attorney Counsel Lawyer Healthcare Compliance Regulatory Compliance Healthcare Law #DiedreMoire #AttorneyJobs #JobSearch #JobHunt #JobOpening #Hiring #Job #Jobs #Careers #Employment #jobposting DISCLAIMER: We will make every effort to consider applications for all available positions and shall use one or more of the contact methods and addresses indicated in resume or online application. Indicated location may be proximate or may be desirable point of embarkation for paid or unpaid relocation to another venue. Job descriptions may fit single or multiple presently available or anticipated positions and are NOT an offer of employment or contract implied or otherwise. Described compensation is not definite nor precise and may be estimated and approximate and is negotiable depending on market conditions and candidate availability and other factors and is solely at the discretion of employers. Linguistics used herein may use First Person Singular and First Person Plural grammatical person construction for and with the meaning of Third Person Singular and Third Person Plural references. We reserves the right to amend and change responsibilities to meet business and organizational needs as necessary. Response to a specific posting or advertisement may result in consideration for other opportunities and not necessarily the incentive or basis of the response. Nothing herein is or may be considered a promise, guarantee, offer, pledge, agreement, contract, or oath. If you submit an application or resume which contains your email address, we will use that email address to communicate with you about this and other positions. We use an email quality control service to maintain security and a remove and dead address filter. To cancel receiving email communications, simply send an email from your address with the word "remove" in the subject line to pleaseremove_AT_candseek4.com Or, visit the website at jobbankremove_dot_com. If you have further concern regarding email received from us, call (609) 584-5499. Reference : Attorney - Senior Counsel - Healthcare Law - Woodbridge, NJ jobs from Latest listings added - cvwing http://cvwing.com/jobs/technology/attorney-senior-counsel-healthcare-law-woodbridge-nj_i12637

[linkhellojobs]

Attorney - Senior Counsel - Healthcare Law - Woodbridge, NJ

Apply legal expertise in healthcare law, including FDA regulatory proficiency and commercial contract experience to advise clients of a North East USA Multi-Office Regional Law Firm. Serve as legal counsel to various clients, advising on structuring and negotiating agreements, dispute resolution, and legal strategy impacting business decisions. Advise clients to promote compliance with industry standards of conduct and ethics, including fraud and abuse, anti-bribery, ant-kickback, and Foreign Corrupt Practices Act (FCPA). Provide advice to clients on legal risks of key business decisions that support strategic initiatives. Negotiate and draft complex commercial contracts and other commercial agreements. Manage prosecution and defense of legal claims, including managing the process and working with clients to ensure efficient and effective outcomes. Receive competitive starting compensation with full medical, dental and vision benefits along with matched 401(k) and performance bonus. Paid time off for personal days, vacations and holidays. Tuition reimbursement for continued education and paid training provided. For complete details contact Greg Foss at: (609) 584-9000 ext 270 Or submit resume online at: dmc9.com/gbf/app.asp Or email to: 1000043988_10006796 AT najbcareers302.com Please reference #39406112 when responding. Education Requirements: Doctorate degree Minimum Experience Requirements: 5-10 years Job City Location: Woodbridge Job State Location: NJ Job Country Location: USA Salary Range: $250,000to $350,000 Diedre Moire Corporation, Inc. Diedremoire_dot_com WE ARE AN EQUAL OPPORTUNITY EMPLOYER and our employment decisions are made without regard to race, color, religion, age, sex, national origin, handicap, disability or marital status. We reasonably accommodate individuals with handicaps, disabilities and bona fide religious beliefs. Jobs Career Position Hiring. CONSIDERED EXPERIENCE INCLUDES: Attorney Counsel Lawyer Healthcare Compliance Regulatory Compliance Healthcare Law #DiedreMoire #AttorneyJobs #JobSearch #JobHunt #JobOpening #Hiring #Job #Jobs #Careers #Employment #jobposting DISCLAIMER: We will make every effort to consider applications for all available positions and shall use one or more of the contact methods and addresses indicated in resume or online application. Indicated location may be proximate or may be desirable point of embarkation for paid or unpaid relocation to another venue. Job descriptions may fit single or multiple presently available or anticipated positions and are NOT an offer of employment or contract implied or otherwise. Described compensation is not definite nor precise and may be estimated and approximate and is negotiable depending on market conditions and candidate availability and other factors and is solely at the discretion of employers. Linguistics used herein may use First Person Singular and First Person Plural grammatical person construction for and with the meaning of Third Person Singular and Third Person Plural references. We reserves the right to amend and change responsibilities to meet business and organizational needs as necessary. Response to a specific posting or advertisement may result in consideration for other opportunities and not necessarily the incentive or basis of the response. Nothing herein is or may be considered a promise, guarantee, offer, pledge, agreement, contract, or oath. If you submit an application or resume which contains your email address, we will use that email address to communicate with you about this and other positions. We use an email quality control service to maintain security and a remove and dead address filter. To cancel receiving email communications, simply send an email from your address with the word "remove" in the subject line to pleaseremove_AT_candseek4.com Or, visit the website at jobbankremove_dot_com. If you have further concern regarding email received from us, call (609) 584-5499. Reference : Attorney - Senior Counsel - Healthcare Law - Woodbridge, NJ jobs from Latest listings added - LinkHello http://linkhello.com/jobs/technology/attorney-senior-counsel-healthcare-law-woodbridge-nj_i9715

[linkhello1]

Attorney - Senior Counsel - Healthcare Law - Woodbridge, NJ

Apply legal expertise in healthcare law, including FDA regulatory proficiency and commercial contract experience to advise clients of a North East USA Multi-Office Regional Law Firm. Serve as legal counsel to various clients, advising on structuring and negotiating agreements, dispute resolution, and legal strategy impacting business decisions. Advise clients to promote compliance with industry standards of conduct and ethics, including fraud and abuse, anti-bribery, ant-kickback, and Foreign Corrupt Practices Act (FCPA). Provide advice to clients on legal risks of key business decisions that support strategic initiatives. Negotiate and draft complex commercial contracts and other commercial agreements. Manage prosecution and defense of legal claims, including managing the process and working with clients to ensure efficient and effective outcomes. Receive competitive starting compensation with full medical, dental and vision benefits along with matched 401(k) and performance bonus. Paid time off for personal days, vacations and holidays. Tuition reimbursement for continued education and paid training provided. For complete details contact Greg Foss at: (609) 584-9000 ext 270 Or submit resume online at: dmc9.com/gbf/app.asp Or email to: 1000043988_10006796 AT najbcareers302.com Please reference #39406112 when responding. Education Requirements: Doctorate degree Minimum Experience Requirements: 5-10 years Job City Location: Woodbridge Job State Location: NJ Job Country Location: USA Salary Range: $250,000to $350,000 Diedre Moire Corporation, Inc. Diedremoire_dot_com WE ARE AN EQUAL OPPORTUNITY EMPLOYER and our employment decisions are made without regard to race, color, religion, age, sex, national origin, handicap, disability or marital status. We reasonably accommodate individuals with handicaps, disabilities and bona fide religious beliefs. Jobs Career Position Hiring. CONSIDERED EXPERIENCE INCLUDES: Attorney Counsel Lawyer Healthcare Compliance Regulatory Compliance Healthcare Law #DiedreMoire #AttorneyJobs #JobSearch #JobHunt #JobOpening #Hiring #Job #Jobs #Careers #Employment #jobposting DISCLAIMER: We will make every effort to consider applications for all available positions and shall use one or more of the contact methods and addresses indicated in resume or online application. Indicated location may be proximate or may be desirable point of embarkation for paid or unpaid relocation to another venue. Job descriptions may fit single or multiple presently available or anticipated positions and are NOT an offer of employment or contract implied or otherwise. Described compensation is not definite nor precise and may be estimated and approximate and is negotiable depending on market conditions and candidate availability and other factors and is solely at the discretion of employers. Linguistics used herein may use First Person Singular and First Person Plural grammatical person construction for and with the meaning of Third Person Singular and Third Person Plural references. We reserves the right to amend and change responsibilities to meet business and organizational needs as necessary. Response to a specific posting or advertisement may result in consideration for other opportunities and not necessarily the incentive or basis of the response. Nothing herein is or may be considered a promise, guarantee, offer, pledge, agreement, contract, or oath. If you submit an application or resume which contains your email address, we will use that email address to communicate with you about this and other positions. We use an email quality control service to maintain security and a remove and dead address filter. To cancel receiving email communications, simply send an email from your address with the word "remove" in the subject line to pleaseremove_AT_candseek4.com Or, visit the website at jobbankremove_dot_com. If you have further concern regarding email received from us, call (609) 584-5499. Reference : Attorney - Senior Counsel - Healthcare Law - Woodbridge, NJ jobs from Latest listings added - LinkHello http://linkhello.com/jobs/technology/attorney-senior-counsel-healthcare-law-woodbridge-nj_i9715

[employmentusanet]

[Full-time] Litigation Associate--Govt Enforcement at StaffingForce

Location: United States Of America URL: https://www.staffingforce.com Description: Noted domestic and international law firm is seeking a Spanish or Portuguese fluent Litigation Associate (JD class of 2014, or 2015, or 2016) to join its Litigation & Enforcement group in Chicago. Candidate Must have the following: 3-5 years of experience working on internal and government investigations, anti-corruption and international risk matters ; Engagement with white-collar, money laundering, fraud, risk assessment and regulatory work, and/or complex commercial litigation matters ; Exposure to global anti-bribery laws, including the Foreign Corrupt Practices Act of 1977 (FCPA), UK Bribery Act, trade sanctions, export control, anti-money laundering, and private equity or sovereign investor transactions ; Experience in a major law firm setting (experience will be current or very recent) ; Native or fluent-level Spanish and/or Portuguese language skills. Stellar academic credentials (Law Review and/or Moot Court accolades desired); Major law firm experience, Strong research, verbal & written communication skills required ; Illinois Bar. Excellent work environment and benefits package with competitive compensation commensurate with experience. Responsibilities include, but are not limited to: -Representing a diverse clientele in various matters including global anti-bribery laws, including the Foreign Corrupt Practices Act of 1977 (FCPA), UK Bribery Act, trade sanctions, export control, anti-money laundering, and private equity or sovereign investor transactions. -Aiding clients in internal and government investigations, anti-corruption and international risk matters, matters involving white-collar, money laundering, fraud, risk assessment and regulatory work, and/or complex commercial litigation matters. -Conducting interviews, interfacing with clients, advising on strategy and managing associate teams. Reference : Litigation Associate--Govt Enforcement jobs Apply to this job from employment-usa.net http://www.employment-usa.net/job/26777/litigation-associate-govt-enforcement-at-staffingforce/

[americajobsnet]

[Full-time] Litigation Associate--Govt Enforcement at StaffingForce

Location: United States Of America URL: https://www.staffingforce.com Description: Noted domestic and international law firm is seeking a Spanish or Portuguese fluent Litigation Associate (JD class of 2014, or 2015, or 2016) to join its Litigation & Enforcement group in Chicago. Candidate Must have the following: 3-5 years of experience working on internal and government investigations, anti-corruption and international risk matters ; Engagement with white-collar, money laundering, fraud, risk assessment and regulatory work, and/or complex commercial litigation matters ; Exposure to global anti-bribery laws, including the Foreign Corrupt Practices Act of 1977 (FCPA), UK Bribery Act, trade sanctions, export control, anti-money laundering, and private equity or sovereign investor transactions ; Experience in a major law firm setting (experience will be current or very recent) ; Native or fluent-level Spanish and/or Portuguese language skills. Stellar academic credentials (Law Review and/or Moot Court accolades desired); Major law firm experience, Strong research, verbal & written communication skills required ; Illinois Bar. Excellent work environment and benefits package with competitive compensation commensurate with experience. Responsibilities include, but are not limited to: -Representing a diverse clientele in various matters including global anti-bribery laws, including the Foreign Corrupt Practices Act of 1977 (FCPA), UK Bribery Act, trade sanctions, export control, anti-money laundering, and private equity or sovereign investor transactions. -Aiding clients in internal and government investigations, anti-corruption and international risk matters, matters involving white-collar, money laundering, fraud, risk assessment and regulatory work, and/or complex commercial litigation matters. -Conducting interviews, interfacing with clients, advising on strategy and managing associate teams. Reference : Litigation Associate--Govt Enforcement jobs Apply to this job from America Jobs http://www.america-jobs.net/job/67240/litigation-associate-govt-enforcement-at-staffingforce/

[golicit]

A Closer Look at FCPA-Related Securities Suits

As I have previously noted, even though the Foreign Corrupt Practices Act (FCPA) does not contain a private right of action, plaintiffs’ attorneys have fashioned an FCPA-based claim of sorts in the form of a follow-on shareholder claim alleging either mismanagement or misrepresentation with respect to the alleged bribery or corrupt activity. A  July 10, 2019 memo by attorneys from the DLA Piper law firm (here) takes a look at securities class action lawsuits filed based on FCPA allegations. As the authors note, the underlying FCPA allegations “do not necessarily make for a successful securities class action,” as most FCPA-related securities fraud claims “are dismissed.” As discussed below, a July 12, 2019 dismissal ruling in the FCPA-related Cemex securities class action illustrates both the kind of securities claims that can arise in the wake of FCPA-related allegations and also the hurdles that these kinds of claims face.

  FCPA-Related Securities Litigation

As the authors of the law firm memo note, allegations of FCPA violations seem to “embolden” plaintiffs’ attorneys to file securities class action lawsuits against the company involved, particularly where the company has made admissions of misconduct in connection with a deferred prosecution agreement or other corporate resolutions. The kinds of misrepresentations on which plaintiffs rely in these cases tend to fall into one of several categories of allegations.

  First, plaintiffs tend to try to “fashion fraud claims” around a company’s statements about its compliance with the law or its own ethics guidelines. As a general matter, these kinds of allegations are dismissed as mere “puffery,” and “explicitly aspirational statements” are also generally found to be not actionable. However, statements about compliance of with antibribery laws can in some circumstances be actionable; the authors cite the Eletrobras securities class action lawsuit where the company’s statements about its commitment to “transparency and ethical conduct” were made in direct response to press reports about the company’s possible involvement in the Operation Car Wash bribery scandal.

  Second, plaintiffs asserting FCPA follow-on claims also tend to try to rely on the company’s statements about the effectiveness of its internal controls. General statements of this type are “generally not actionable” because they are “too vague or boilerplate.” However, these allegations can be successful where the alleged statements reflected an opinion on the efficacy of the internal controls and the plaintiff was able to allege that the speaker was aware the opinion was false.

  Third, plaintiffs may seek to allege misrepresentations based on the defendant company’s failure to disclose FCPA-related risks or payments. As a general matter, there is “no freestanding duty” for companies to disclose corruption risk or even uncharged wrongdoing. The risk of liability may arise where the company discusses the reasons for its success, creating an obligation to “tell the whole story,” even if it includes illegal conduct. The authors cite the Braskem case, where the court agreed that the company’s statements about the bases for the prices the company paid for certain raw materials was actionable; the company had advanced a number of innocuous reasons for the low prices, but omitted to mention that the prices were established pursuant to a side agreement under which the company paid substantial bribes.

  As a general matter, the authors note that claimants in these kinds of follow-on securities suits “struggle to identify statements that rise to the level of a material misstatement.” As a result, most of these kinds of claims are dismissed. However, there are exceptions to this generalization, and as I note below, even though most of these cases are dismissed, there have been several very large settlements of FCPA-related securities suits.

  The July 12, 2019 Ruling in the Cemex Case

Many of the shortcomings the law firm authors note in their memo were present in the securities class action lawsuit involving Cemex. As noted here, in 2018, plaintiff shareholders had filed a securities class action in the Southern District of New York against Cemex, a multinational building-materials company based in Mexico, and certain of its directors and officers.

  The allegations in the securities suit related to the company’s efforts to build a new cement plant in Columbia. While the project was in progress, Cemex disclosed that it had commenced litigation in Columbia related to its efforts to purchase land, mining rights, and tax benefits from a Columbian counterparty. Throughout this period, Cemex made a serious of statements about its internal controls and its compliance with anti-bribery laws, as well as with its own internal Code of Ethics.

  In the fall of 2016, Cemex announced that as a result of internal audit processes, it had uncovered approximately $20 million in payments to the Columbian counterparty in connection with the acquisition of land, mining rights and tax benefits. The payments, the company said, had been made in violation of the company’s policies and applicable law. In the following months, Cemex disclosed that it had been subpoenaed by the SEC and the DOJ as part of an investigation whether the payments violated the FCPA. In April 2017, the company revealed that it had uncovered a material weakness in its internal controls over financial reporting.

  In their complaint, the plaintiff shareholders alleged: (1) that the company misleadingly failed to disclose the bribery scheme when disclosing information about the Columbian project; (2) attributed the company’s growth to various factors without disclosing the role that the bribery scheme played; (3 ) falsely stated that the company and its employees complied with the company’s Code of Ethics and with applicable anti-bribery laws; and (4) made false statements about the effectiveness of its internal controls over financial reporting. The court concluded as a matter of law that all of these allegations were inactionable except the first category.

  In her July 12, 2019 opinion in the case (here), Judge Valerie Caproni ruled with respect to the supposed failure to disclose that the bribery was an important component of the company’s success that these statement were “far too generic to be actionable,” adding that “it is not at all clear whether the bribery scheme played a role in the company’s growth or success.”  Judge Caproni also held that the company’s statements about compliance with its own Code of Ethics and anti-bribery laws were “inactionable puffery,” because they were “too general to cause a reasonable investor to rely on them.” Many of the statements were preceded with “explicitly aspirational language,” signaling that the statements were “about goals, not statements of fact.” Finally, with respect to the plaintiffs allegations about internal controls, Judge Caproni noted that the statements on which the plaintiffs sought to rely did not state that the internal controls were effective, only that management had concluded the controls were effective. The plaintiffs, Judge Caproni said, had not alleged that management had not so concluded.

  Judge Caproni did conclude that the plaintiffs had adequately alleged misrepresentation with respect to the company’s failure to disclose the bribery scheme in connection with the Columbia project. Judge Caproni said that the alleged bribery scheme had a “direct nexus” to Cemex’s efforts to acquire the requisite land, mining rights, and tax benefits. Armed with information about the scheme, an investor could reasonably have questioned with the rights to these various assets were legally enforceable.

  However, while Judge Caproni concluded that the plaintiffs had sufficiently alleged a misrepresentation with respect to the failure to disclose the bribery scheme, she further concluded that the plaintiffs had failed to sufficiently allege that the statements or omissions were made with scienter. She rejected the plaintiffs’ arguments that the resignation of several company officials at the time the improper payments were revealed established scienter, and she also rejected the contention that various supposed “red flags” established the existence of a culture of corruption sufficiently to establish scienter.

  Judge Caproni granted the defendants’ dismissal motion but granted the plaintiffs leave to amend, noting that she is “skeptical that the flaws in the Amended Complaint can be remedied.”

  Discussion

Judge Caproni’s opinion in the Cemex case corroborates the generalization in the law firm memo that plaintiffs in FCPA-related securities suit face difficulties in establishing that the defendant companies made actionable misstatements, even where the companies have made admissions that improper payments took place. Indeed, many of the allegations in the Cemex  case raised track closely with the law firm memo’s authors observations about the kinds of allegations that plaintiffs in these kinds of cases tend to raise. Judge Caproni’s opinion shows even armed with company admissions it is difficult for plaintiffs to establish that the company made actionable misrepresentations to investors.

  Despite these kinds of difficulties, plaintiffs’ attorneys continue to file these kinds of cases. For example, during 2019, plaintiffs’ lawyers have filed bribery-related securities class action lawsuits against Mobile Telesystems PJSC (about which refer here) and against China Cache International Holdings Ltd (here). The Mobile Telesystems lawsuit is discussed at length in a prior post here.

  There is one very good reason why plaintiffs’ lawyers continue to file these kinds of lawsuits despite the long odds, and that is that if they can figure out a way to get based the motion to dismiss hurdle, these cases can be highly remunerative. The most extreme example of this principle is the high-profile case involving Petrobras, which settled in early 2018 for $3 billion, one of the largest U.S. securities class action lawsuits ever.

  The Petrobras settlement is obviously something of an outlier, but it is not the only recent high dollar-figure settlement in FCPA-related securities class action lawsuits. For example, the series of settlements in the FCPA-related Cobalt International Energy securities suit total approximately $389.6 million. The bribery related securities suit against Wal-Mart Stores settled for $160 million. The FCPA-related securities suit against Avon Products settled for $62 million. There has been a host of other settlement in FCPA-related suits.

  There are a couple of other points worth making concerning these FCPA-related lawsuits. As the suits against Cemex and Petrobras demonstrate, many of these lawsuits involve companies based outside the U.S. Indeed the possibility of these kinds of lawsuits is one of the factors that helps to explain the elevated U.S. securities litigation frequency exposure of U.S.-listed non-U.S. companies.

  The other thing worth point out about these FCPA-related lawsuits is that these cases are yet another example of the kind of event-driven litigation that has come to be such a significant factor in securities litigation filings in recent years. The exposure to these kinds of claims is not the kind of risk that can be identified by the kind of financial statement review and analysis that is the traditional basis of public company D&O insurance underwriting – although, to be sure, companies that are doing business in certain obvious high-risk jurisdictions obviously are at greater risk of becoming involved in bribery or corruption investigations.

  In any event, notwithstanding the hurdles that plaintiffs’ lawyers face in trying to pursue FCPA-related securities claims, the likelihood is that they will continue to file these kinds of claims. Even though, as I have previously noted, that while these kinds of cases frequently are filed, they also are frequently dismissed. The ones that survive the dismissal motion can, however, be quite dangerous.

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