such companies generally are required by federal and
Every indexed document
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69,179 documents
available at http://www.sec.gov/litigation/
available at http://www.sec.gov/about/forms/
17 C.F.R. § 240.15d-15; Item 308 of Regulation S-K
available at http://www.justice.gov/criminal/fraud/fcpa/cases/
supra note 48 (bribes paid to foreign officials to secure
Siemens AG and Three Subsidiaries Plead Guilty to Foreign
the accounting requirements and criminal [antibribery]
runs from the last overt act during the existence of
unless the indictment is found or the information is instituted
shall be deemed to be in violation of such
available at http://www.justice.gov/opa/pr/2012/
ECF No. 1 [hereinafter SEC v. El Paso Corp.] (charging company
available at http://www.justice.gov/criminal/fraud/fcpa/
966 (2009) (“Allowing a company to escape its debts and
including liability for unlawful payments
In the Matter of United Industrial Corp.
Exchange Act Release No. 61325 ( Jan. 11
was charged with civil violations of the
which eventually discovered these payments