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Bob Appleton Quoted in Law360 Article on BHP Bilton's $25 Million FCPA Fine

Publisher: Law360
May 22, 2015

Bob Appleton was quoted in the article, "SEC Flexes Bigger FCPA Muscles In $25M BHP Billiton Case," in Law360. In the piece, Appleton comments on the significance of the U.S. Securities and Exchange Commission's $25 million fine against BHP Billiton for violating the Foreign Corrupt Practices Act, which focused solely on the failures of the company to adopt sufficient internal controls to prevent the risks of a violation, rather than a violation itself. The case is significant for the fact that there was no actual contract that was procured through bribery that underpinned the conviction and sentence. The importance of the case, Appleton stated, was that the SEC addressed only the deficiencies in the compliance program as the sole basis for the prosecution.


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