EFTA01080289.txt

"Lanny A. Breuer Assistant Attorney General Criminal Division Department of Justice"

"Robert S. Khuzami Director of Enforcement Securities and Exchange Commission"

"The Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) share FCPA enforcement authority"

"The Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) share FCPA enforcement authority"

"The Anti-Bribery Convention came into force on February 15, 1999, with the United States as a founding party."

"FCPA matters are handled primarily by the FCPA Unit within the Fraud Section"

"Within DOJ, the Fraud Section of the Criminal Division has primary responsibility for all FCPA matters"

"34 OECD member countries (including the United States) and five non-OECD member countries... All of these parties are also members of the OECD Working"

"five non-OECD member countries (Argentina, Brazil, Bulgaria, the Russian Federation, and South Africa). All of these parties are also members of the O"

"five non-OECD member countries (Argentina, Brazil, Bulgaria, the Russian Federation, and South Africa). All of these parties are also members of the O"

"five non-OECD member countries (Argentina, Brazil, Bulgaria, the Russian Federation, and South Africa). All of these parties are also members of the O"

"five non-OECD member countries (Argentina, Brazil, Bulgaria, the Russian Federation, and South Africa). All of these parties are also members of the O"

"five non-OECD member countries (Argentina, Brazil, Bulgaria, the Russian Federation, and South Africa). All of these parties are also members of the O"

"The United States is a state party to the United Nations Convention Against Corruption (UNCAC)... The United States ratified the UNCAC on October 30, "

"The IACAC requires parties (of which the United States is one) to criminalize both foreign and domestic bribery"

"GRECO member states... include more than 45 European countries and the United States"

"The Council of Europe established the Group of States Against Corruption (GRECO) in 1999"

"Company A's proposed acquisition would make Foreign Company a subsidiary of Company A"

"Foreign Company has made several potentially improper payments in the form of an inflated commission to a third-party agent"

"Company A discloses the conduct to DOJ and SEC"

"Company A discloses the conduct to DOJ and SEC"

"an employee in Company A's international sales office (Sales Employee)"

"In United States t Kazin", the defendant unsuccessfully sought to assert the local law defense"

"SEC's framework for evaluating cooperation by companies is set forth in its 2001 Report... commonly known as the Seaboard Report"

"SEC's Seaboard Report focuses, among other things, on a company's self-policing"

"three of the nine factors set forth in DOD's Principles of Federal Prosecution of Business Organizations"

"in April 2010, SEC charged four individuals—a Country Manager"

"in April 2010, SEC charged four individuals—a Senior Vice President of Sales"

"in April 2010, SEC charged four individuals—a Regional Financial Director"

"in April 2010, SEC charged four individuals—an International Controller"

"its executive pleaded guilty to conspiracy to violate the FCPA's internal control provisions"

"and also settled with SEC"

"only DOJ has the authority to pursue criminal actions... under the FCPA"

"both DOJ and SEC have civil enforcement authority under the FCPA"

"Department of State's Directorate of Defense Trade Controls (DDTC)"

"the company's senior vice president of international sales (Sales Executive)"

"Company A enters into a consulting contract with the local businessman (Consultant)"

"One of the principals (Principal 1) of the Local Partner"

"Company A learns about a potential $50 million contract with the country's Ministry of Immigration"

"Sales Executive received a large year-end bonus due to the award of the contract"

"Under its company polity... Company A requires both finance and compliance approval. The finance officer is concerned"

"The compliance officer focuses his due diligence on vetting Distributor"

"Principal 1 is a former college roommate of a senior official of the Ministry of Immigration"

"finance officer approves Company A's payments to Local Partner via the offshore account"

"Local Partner and Distributor used part of the payments... to funnel bribe payments to several Ministry of Immigration officials, including Principal "

"Local Partner and Distributor used part of the payments and discount margin, respectively, to funnel bribe payments to several Ministry of Immigration"

"Distributor has established an off-shore bank account for the transaction"

"Local Partner... has established an off-shore shell company and bank account to conduct this transaction"

"Thousands of dollars are also wired to the personal offshore bank account of Sales Executive"

"In May of 2011, SEC entered into its first deferred prosecution agreement against a company for violating the FCPA... a global manufacturer of steel p"