Anti-corruption/FCPA, International Trade – The latest on Embraer and Weatherford FCPA cases, the SEC and the New Anti-Corruption Law in Brazil.
Aircraft giant Embraer SA is under investigation by U.S. and Brazilian authorities amid allegations that it made improper payments to a government official in the Dominican Republic.Embraer is being probed over allegations that its executives made bribery payments to officials in the Dominican Republic in exchange for a $90 million contract to furnish the country’s armed forces with military planes, according to documents obtained by
The Wall Street Journal. [
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Weatherford International Ltd. said it reached agreements with U.S. authorities to resolve foreign bribery allegations, corruption in Iraq and sanctions violations. [
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On October 24, the SEC
released a
cease-and-desist order that resolves FCPA allegations against a Michigan-based medical technology company. The SEC alleged that the company’s subsidiaries in five different countries—Argentina, Greece, Mexico, Poland, and Romania—bribed doctors, health care professionals, and other government officials to obtain or retain business. The alleged activities involved approximately $2.2 million in direct payments, travel and conference expenses, and donations to a university associated with a foreign official made over a four-and-a-half year period. [
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Earlier this year, the Brazilian government approved a sweeping anti-corruption law known as the Brazilian Clean Companies Act (“BCCA” or “Act”), which is set to take effect on January 29, 2014. The new law provides for a wide range of administrative and legal penalties for violators, and is as broad as—if not broader than— the U.S. Foreign Corrupt Practices Act (“FCPA”). As Brazil’s economy continues to surge, and the Brazilian government continues to promote a vigorous anti-corruption agenda, companies that do business in Brazil must ensure that their policies and procedures are satisfactory. [
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Tags: Anti-corruption, Bribery, FCPA, International Trade, Sanctions Settlements