Morrison Foerster released thereport, The Expansive Reach of the FCPA Extends to Japan Again: A Second Japanese Company Resolves FCPA Charges Related to a Nigerian Bribery Scandal
Introduction
On Tuesday, January 17, 2012, the U.S. Department of Justice (“DOJ”) filed a deferred prosecution agreement requiring Marubeni Corporation (“Marubeni”) to pay $54.6 million in criminal penalties for its participation in a conspiracy to bribe Nigerian officials in violation of the U.S. Foreign Corrupt Practices Act (“FCPA”). The deferred prosecution agreement requires Marubeni to retain a corporate compliance consultant for two years and to cooperate with the DOJ’s ongoing investigations. The criminal charges against Marubeni will be dropped after two years so long as Marubeni abides by the terms of the deferred prosecution agreement. Marubeni is the fourth non-U.S. company, and the second Japanese company, to face criminal charges in this matter. The charges against Marubeni are yet another stark reminder of the DOJ’s interpretation of the FCPA’s expansive jurisdictional reach.
To view full text: http://bdti.or.jp/english/data_library#gallery-725d62986bc7e80e1222f03304f7814b2302e66793e13ccee38ed91201fc3e39
The Board Director Training Institute (BDTI) is a "public interest" nonprofit in Japan dedicated to training about directorship, corporate governance, and related management techniques. It is certified by the Japanese government to conduct these activities as a regulated nonprofit. Read a summary about BDTI here, and see a menu of its services for both corporations and investors here.