Rebekah Poston

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So You Think Tailored FCPA Training Does Not Matter? – Think Again

Ask the bank that just paid the SEC more than $ 6 million for failing to adequately train its Asia Pacific Region (APAC) personnel on antibribery with respect to hiring practices.  The bank had policies against hiring personnel in exchange for business, but, according to the SEC’s order, the company “failed to effectively train APAC … Continue Reading

Brazil Strengthens Battle Against Corruption

In August 2018, in an effort to battle corruption, Brazil enacted Decree-Law No. 9,468/18, which provides broader power to the Public Transparency and Anti-Corruption Council.  The Council’s purpose is to discuss ideas and suggestions to improve policies and strategies aimed at combating corruption and impunity within the Federal Public Administration. For a closer look at … Continue Reading

SEC Staying the Course on FCPA Enforcement

In remarks at NYU’s Program on Corporate Compliance and Enforcement, Steven Peikin, the new Co-Director of the SEC’s Enforcement Division, voiced a question that has been on the minds of many anticorruption practitioners and compliance professionals: Will the SEC continue to be committed to robust FCPA enforcement?”   “My answer to that question is simple,” Peikin … Continue Reading

Monthly China Anti-Bribery Update Report – November 2016

1. New laws or regulations State level: No developments. Local level (Beijing & Shanghai): No developments. Communist Party Rules: No developments. 2. Upcoming laws or regulations No developments. 3. Government Action (1) It was reported on November 4, 2016 that Zhuang Yao (“Zhuang”), the former Chairman of Guangdong Materials Group Co., Ltd. (“GMGC”), a state-owned … Continue Reading

Monthly China Anti-Bribery Update Report — September 2016

1. New laws or regulations State level: No developments. Local level (Beijing & Shanghai): No developments. Communist Party Rules: No developments. 2. Upcoming laws or regulations No developments. 3. Government Action (1) On September 2, 2016, Wei Xinhong (“Wei”), the former Party Secretary of Qinyang Municipal, Henan Province, was sentenced by the Intermediate People’s Court … Continue Reading

Monthly China Anti-Bribery Update Report — August 2016

1. New laws or regulations State level: No developments. Local level (Beijing & Shanghai): No developments. Communist Party Rules: No developments. 2. Upcoming laws or regulations No developments. 3. Government Action (1) On August 2, 2016, Hu Xuefan (“Hu”), the former Director of Tourism Bureau of Anhui Province, was sentenced by the Intermediate People’s Court … Continue Reading

Monthly China Anti-Bribery Update Report — July 2016

1. New laws or regulations State level: No developments. Local level (Beijing & Shanghai): No developments. Communist Party Rules: (1) On July 17, 2016, the Central Commission for Discipline Inspection issued the Accountability Regulations of the Communist Party of China (the “Regulations”). The Regulations specify the intra-Party accountability mechanism for the serious consequences caused by … Continue Reading

Monthly China Anti-Bribery Update Report — June 2016

1. New laws or regulations State level: No developments. Local level (Beijing & Shanghai): No developments. Communist Party Rules: No developments. 2. Upcoming laws or regulations No developments. 3. Government Action (1) In early June, Zhang Longjun (“Zhang”), the former Dean of Shangyu Traditional Chinese Medicine Hospital (the “Hospital”), together with Chen An (“Chen”) and … Continue Reading

Monthly China Anti-Bribery Update Report — May 2016

1. New laws or regulations State level: No developments. Local level (Beijing & Shanghai): No developments. Communist Party Rules: No developments. 2. Upcoming laws or regulations No developments. 3. Government Action (1) It was reported on May 6, 2016 that Wang Tianchao (“Wang”), the former President of Yunnan First People’s Hospital, was prosecuted by Pu’er … Continue Reading

Monthly China Anti-Bribery Update Report — April 2016

1. New laws or regulations State level: (1) On April 18, 2016, the Supreme People’s Court and Supreme People’s Procuratorate promulgated Interpretations of the Supreme People’s Court and the Supreme People’s Procuratorate on Certain Issues Concerning the Application of Law in Handling Criminal Cases Involving Embezzlement and Bribery (the “Interpretations”). Key highlights of the Interpretations … Continue Reading

Monthly China Anti-Bribery Update Report — March 2016

1. New laws or regulations State level: No developments. Local level (Beijing & Shanghai): No developments. Communist Party Rules: No developments. 2. Upcoming laws or regulations No developments. 3. Government Action (1) It was reported on March 4, 2016 that Haikou Intermediate People’s Court had affirmed the sentence of Liao Yongyu (“Liao”), the former Office … Continue Reading

Monthly China Anti-Bribery Update Report – February 2016

1. New laws or regulations State level: No developments. Local level (Beijing & Shanghai): No developments. Communist Party Rules: No developments. 2. Upcoming laws or regulations No developments. 3. Government Action (1) On February 17, 2016, Zhou Peifang (“Zhou”), the former Director of Beijing Haidian District Municipal Garden Service Center and Haidian District Municipal Commission … Continue Reading

China’s Amendment to the Criminal Law to Outlaw Bribery of Foreign Officials Becomes Effective

An amendment of the PRC Criminal Law which criminalizes bribery of foreign government officials and “international public organizations” to secure illegitimate business benefits went into effect on May 1, 2011. The PRC did not have any law addressing cross-border bribery before and this law will be the first law to condemn bribery of foreign officials. This … Continue Reading
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