Compendium Roundup: February 2016

Compendium Roundup: February 2016

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March 01, 2016

There were a number of enforcement actions in the United States this month. VimpelCom Ltd. agreed to pay more than US $835 million in disgorgement and penalties to settle charges brought by the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) that the company violated the anti-bribery and books and records and internal controls provisions of the U.S. Foreign Corrupt Practices Act (“FCPA”) by making at least US $114 million in improper payments to a relative of the President of Uzbekistan to enter and remain in the Uzbek telecom market.  The settlement includes disgorgement and penalties paid to settle charges by the Public Prosecution Service of the Netherlands.

PTC Inc. agreed to pay more than US $28 million to the DOJ and the SEC to resolve allegations that the Company violated the anti-bribery and books and records and internal controls provisions of the FCPA by providing approximately US $1.5 million in travel, gifts and entertainment to officials to secure and retain sales to Chinese state-owned entities. PTC subsidiaries spent more than US $274,000 on gifts and entertainment for Chinese officials and paid US $1.1 million for Chinese officials to travel to places like New York, Las Vegas and Honolulu.

SciClone Pharmaceuticals (“SciClone”) agreed to pay more than US $12 million to the SEC to settle charges that it violated the FCPA by making improper payments to health care professionals at state-owned hospitals in China. Employees of SciClone subsidiaries allegedly gave gifts and money to Chinese health care professionals and paid for Chinese officials to travel to places like Disneyland and the Grand Canyon to encourage sales of SciClone products.

SAP SE agreed to pay more than US $3.7 million in disgorgement and prejudgment interest to settle charges brought by the SEC that SAP violated the books and records and internal controls provision of the FCPA by allowing an employee to pass on large discounts to a Panamanian partner, thereby creating a slush fund from which to pay bribes to Panamanian officials.

Visit the TRACE Compendium to view the complete entries, along with other updates from this month. 

Strategic Due Diligence - Active Engagement
Eradicating Corruption
Compendium Roundup: February 2016

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