Skip to content

Compliance Building

Doug Cornelius on compliance for private equity real estate

Menu
  • Home
  • About
    • About
    • About Doug
    • About This Website
    • Why I Blog
    • Speaking Engagements
    • Contact
    • Publications
  • Archives
    • Topic Archive
    • Book Reviews
    • Most Popular
  • Subscribe
  • Disclaimers
    • Disclaimers
    • Policies and Procedures
    • Use of Site Content
    • Comments
    • FTC Disclosure
Menu

It Does Not Take Much to Get You Into FCPA Trouble

Posted on July 19, 2010December 18, 2012 by Doug Cornelius
Print Friendly, PDF & Email

The recent FCPA enforcement actions brought against Veraz Networks, Inc. shows that it does not take huge piles of money to get in trouble. Veraz admitted to making improper payments of only $40,000.

Not that $40,000 is an insignificant amount. It just pales in comparison to the huge dollars we have seen on other FCPA enforcement actions.

That $40,000 in improper payments led to a $300,000 fine and $3,000,000 of investigation expenses.

Back in 2008 Veraz was involved in an SEC investigation that resulted in the company not being able to timely file its 10Q for March 31, 2008. The FCPA violation was uncovered by the company during this investigation. It’s not clear what the original SEC investigation was focused on, but I would guess it was not FCPA violations. They were merely a byproduct of another investigation.

What lessons can we learn from the Veraz?

It does not take a lot of zeros to have an FCPA violation. It’s clear from the statute that even a nominal amount can be a violation.

FCPA violations are on the SEC’s checklist when they start poking around. The SEC is getting easy wins from the FCPA.

Sources:

  • SEC Complaint Against Veraz Networks
  • SEC press Release – SEC Charges California Telecommunications Company With FCPA Violations
  • SEC Litigation Release – SEC Charges California Telecommunications Company With FCPA Violations
  • Veraz Networks April 30, 2010 10Q
  • Veraz Networks June 30, 2010 8K
  • Disconnected … Another Telecommunications Company Settles An FCPA Enforcement Action by Mike Koehler in FCPA Professor
  • When a Rose is not a Rose but an FCPA Violation by Thomas Fox in Corporate Compliance Insights
  • Former SEC FCPA Enforcement Attorney Critical of SEC’s Recent Veraz Networks Inc. Enforcement Action by Mike Koehler in Corporate Compliance Insights

Share this:

  • Print (Opens in new window) Print
  • Share on Facebook (Opens in new window) Facebook
  • Share on LinkedIn (Opens in new window) LinkedIn
  • Share on X (Opens in new window) X
  • Email a link to a friend (Opens in new window) Email

Leave a ReplyCancel reply

This site uses Akismet to reduce spam. Learn how your comment data is processed.

Search for Stuff

Recent Stories

  • No Insider Trading Too Small
  • Cancel-Rebill and Screw Your Clients
  • New Risk Alert on Investment Adviser Annual Compliance Reviews
  • When Compliance Says “Do It”, But the Firm Doesn’t
  • Extending Compliance Dates for Form PF
  • The Massive Scope of Digital Asset Investment Scams
  • SEC Proposes Rescission of Political Contribution Rule for Investment Advisers
  • Is Failure to Disclose Misappropriation Committing Securities Fraud?
  • SEC Sweep of Fake Form ADV Filers
  • New Custody Rule Is On Its Way

Fight Cancer

Please support my Pan-Mass Challenge
Make a donation to fight cancer. donate.pmc.org/DC0176
pan-mass challenge badge

I am a lawyer, but I am not your lawyer. Since I’m a lawyer, this website may be considered attorney advertising under the ethical rules of certain jurisdictions. Please read my disclaimers page before taking any action. And then, don't take any action based on what I wrote.

Creative Commons logo with the text 'Some Rights Reserved' and three symbols representing attribution, non-commercial use, and share alike.

Compliance Building - by Doug Cornelius is licensed under a Creative Commons Attribution-Noncommercial 3.0 United States License.

© 2026 Compliance Building | Powered by Superbs Personal Blog theme