The Securities and Exchange Commission (“SEC”) recently penalized a public company for violating U.S. economic sanctions. The violation cited the “books and records” and “internal controls” provisions of Securities Exchange Act of 1934 (the “Exchange Act”). With this unprecedented action, the SEC has put companies on notice that the Department of Justice (the “DOJ”) and … Continue Reading
The Department of Justice and Securities and Exchange Commission have stressed the need for companies to conduct FCPA due diligence before entering into transactions with third parties or buying another company. The DOJ and SEC have levied stiff fines on companies that have not heeded their advice once violations of the FCPA have been discovered. … Continue Reading
Ball, an Indiana corporation based in Colorado that manufactures metal packaging for household goods, food and beverages, and provides aerospace and technological services, resolved an enforcement action in which the SEC alleged it violated the FCPA’s books and records and internal controls provisions. Conduct The SEC alleged Ball, through a subsidiary, Formametal, S.A., acquired in … Continue Reading
