Reminder: FCPA Charges Can Focus On Improper Gifts Alone
Law360, New York (November 26, 2014, 10:08 AM EST) -- The U.S. Securities and Exchange Commission recently announced fines for two former defense contractor employees for Foreign Corrupt Practices Act violations relating to gifts given to Saudi officials. The individuals, Stephen Timms and Yasser Ramahi, each consented to the entry of settled administrative proceedings and agreed to pay $50,000 and $20,000 in fines, respectively. According to the SEC, in 2008 and 2009 the two men (employees of Boston-based FLIR Systems Inc. at the time and each a U.S. citizen) gave Saudi officials luxury watches and a 20-night multicontinent trip to win contracts for binoculars and security cameras. This enforcement action is noteworthy for being one of very few premised solely on improper gifts....
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