Global Regulatory Enforcement Law Blog : Global Regulatory Enforcement Lawyers & Attorneys: Reed Smith Law Firm: Government Contracts & Compliance

This post was written by James A. Rolfes.

Last week, the Washington Post reported the SEC had rejected a proposed settlement of SEC’s landmark case seeking enforcement of the so-called “clawback” of executive compensation under Sarbanes Oxley Section 304. See Hilzenrath, D., Washington Post July 20, 2011, SEC Rejects Proposal. In SEC v. Jenkins, No. 09-cv-01510 (D. Ariz. filed Jul. 22, 2009), the SEC for the first time sought over $4 million in incentive-based compensation from an admittedly non-culpable CEO of a company that had misstated its financial statements due to employee fraud. The SEC further had obtained an early victory in that case, persuading the federal court that SOX 304 did not require a showing that the defendant CEO aided or even knew about the fraud leading to financial statement restatement. SEC v. Jenkins, 718 F. Supp. 2d 1070 (D. Ariz. 2010). Now the Commissioners have rejected the settlement recommendation of the SEC enforcement staff and accepted the risk that trial of the matter could undo this victory -- signaling perhaps the Commission’s intention to aggressively pursue clawbacks.

Behind the scenes, however, the rejection of the settlement provides a less clear message. According to unnamed sources, some Commissioners balked at a settlement that obtained less than half the sought-after compensation, but others rejected the staff’s recommendation claiming the SEC should never have brought the case in the first place. That tension reflects a wider debate now on going as to whether SOX 304 enforcement against “innocent” CEOs and CFOs represents an intended tough Congressional mandate to punish executives who oversee the filing of later-restated financial statements, or a poor policy choice by the SEC. See e.g., Harvard law School Forum on Corporate Governance and Financial Regulation.

That divergence of Commissioner opinion may also play out as the SEC undertakes to establish rules required under Dodd-Frank 954. That legislation mandated expanded restatement-based clawback requirements, and directed the SEC to craft rules requiring public companies to recover incentive-based compensation calculated using erroneous financial data. See Dodd-Frank Leaves Clawback Uncertainty, Compliance Reporter (August 30, 2010) Rolfes, J.  Right now, the SEC has placed that rulemaking responsibility on hold at least until the Fall 2011.
 

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This post was written by Marjorie C. Holmes and Angela Gregson.

There has been a perception that Asian companies have received unfair treatment at the hands of the European Commission over the years. Three recent appeal cases brought by Mitsubishi Electric Corp (“Mitsubishi”), Toshiba Corp (“Toshiba”) and Fuji Electric Company Ltd (“Fuji”) appear to confirm this as fact. However, the wrong caused by the European Commission’s unequal or unfair treatment of Mitsubishi, Toshiba and Fuji was fully rectified on appeal when the Court completely removed (and in Fuji’s case reduced) the unfairly inflated fines that the European Commission had imposed on the three companies.

In 2007 the European Commission (the “Commission”) imposed fines of €750.71 million on twenty European and Japanese companies for their participation in a cartel on the market for gas insulated switchgear.

Nine companies brought appeals against the Commission's decision. On 12 July 2011, the European General Court (the “Court”) handed down judgments in appeals brought by the Japanese companies, Mitsubishi, Toshiba, Fuji and Hitachi Ltd. In the appeal cases brought by Mitsubishi and Toshiba respectively, the Court found that, by using a different basis for calculating the level of fine to that used in respect of the European producers, the European Commission had breached the principle of equal treatment.

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The last eighteen months have seen numerous new sanctions regimes introduced by the EU, UN and the U.S. Reed Smith has issued a series of Client Alerts already this year as and when new or changed sanctions regimes have been introduced. Amongst the energy and commodity trading and the shipping communities, there has naturally been a heavy focus on Iranian, Ivory Coast and Libyan sanctions. It is important to understand, however, that there are now a whole host of countries facing sanctions from the EU, UN and U.S. Whilst the sanctions position is fast moving, we thought it sensible to draw all of these together in one place.

To view the entire alert please click here.
 

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This post was written by Steven D. Tibbets and Lorraine M. Campos.

 There is a long history of federal court cases distinguishing which items of information that contractors disclose to the Government may be obtained by the public and which items may not. Currently, there is much debate regarding how well the relatively new Federal Awardee Performance and Integrity Information System accomplishes the goal of providing public access to contractor responsibility information.

On a related front, on May 26, 2011, the Office of Governmentwide Policy in the U.S. General Services Administration (“GSA Office”) issued a notice explaining exactly which elements of the Government Central Contractor Registration (“CCR”) are subject to Freedom of Information Act (“FOIA”) requests and which are not. Virtually any person or company that sells any goods or services to, or receives financial assistance in the form of grants, from the federal Government provides information to the Government that is subject to FOIA. There are 260 distinct data fields that contractors may be required to complete – most data fields apply to all contractors, but a few fields apply only to contractors that perform contracts over certain dollar thresholds. Information submitted in completing these fields is presumptively subject to FOIA – as is all information submitted to the federal Government – but GSA has determined some fields are exempt.

Specifically, data fields 156 and 165 through 260 are exempt from FOIA. These fields cover information regarding contractors’ corporate parents, “Austin Tetra” and “Dun & Bradstreet Monitoring” information regarding contractors’ creditworthiness, information regarding security clearances, information regarding executive compensation, and information regarding proceedings involving poor contract performance, fraud, and similar matters. Examples of non-exempt data fields include: (1) average number of employees (field 144); (2) the identity of the owner(s) of the company (field 137); and (3) the company’s annual revenue (field 145).

It is currently not clear whether industry watchdogs, journalists, or contractors seeking information about a competition or an interesting contract award will challenge GSA’s determinations regarding which items of information are exempt from FOIA. In addition, it is not clear how GSA’s findings will apply to or influence determinations regarding the scope of information that is publicly-available via the FAPIIS database. What is clear is that, for now, a great deal of information contractors furnish to the Government via the CCR system will be kept from public view.
 

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This post was written by Steven D. Tibbets and Lorraine M. Campos.

In early 2011, Congress passed the James Zadroga 9/11 Health and Compensation Act of 2010 (“9/11 Act”). A last-minute amendment to the statute imposed a two-percent excise tax on foreign contractors to fund health benefits for 9/11 emergency responders. The tax has been much remarked-upon, but we want to highlight a fantastic bit of scholarship that helps to understand the context and fundraising effectiveness of the tax.

In her paper titled “The Revenue Impact of the 2% Excise Tax”, Nicole R. Best sets forth an economic analysis of the statute and concludes that the revenue-generating estimates of a Congressional Budget Office (“CBO”) report – concluding that the tax would be an effective revenue-generator – were incorrect. (The paper apparently was presented as part of an academic conference and copies are available only through a paid subscription service). The reason? CBO completely failed to account for the treatment of foreign contractors under U.S. procurement laws.

Under the 9/11 Act, any “foreign person that receives a specified Federal procurement payment” must pay a tax equal to 2 percent of the amount of a “specified Federal procurement payment.” However, the tax applies only to contracts for goods manufactured outside the United States and outside certain countries that are parties to “non-discrimination” trade treaties with the U.S. (i.e., “designated countries” under the Trade Agreements Act). Now, generally speaking, when the value of a procurement of tangible goods is under a particular dollar threshold, only U.S.-manufactured goods are eligible for the procurement. When the value is over the threshold, only U.S.- or designated country-manufactured goods are eligible. Products from non-designated countries – the only products that trigger the foreign contractor tax – are never eligible. As such, the foreign contractor tax applies to products that the U.S. government would not purchase anyway. Therefore, as a practical matter, contractors from outside the United States can take comfort in the fact that the tax probably does not apply to them.

Best’s paper goes on to point out additional mathematical and empirical errors that were inherent in the CBO’s estimates. From a policy perspective, Best’s arguments invite scrutiny of the flimsiness of the CBO’s calculations processes that led to their use. Why impose a tax that will not raise money? Does the tax serve a symbolic purpose of some sort? What drove CBO’s error – was it just ignorance of the Trade Agreements Act? Why single out foreign contractor’s for a tax in the first place, particularly one tied to September 11? To serve some sort of nationalistic impulse? Neither Best’s paper nor any other source of which we are aware answers these questions. Nevertheless, they are questions that get to the impetus for public policies affecting firms involved in cross-border government contracts work. Such firms would be well-advised to examine these forces that shape the policies with which they must live.
 

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This post was written by Christoper L. Rissetto, Philip G. Lookadoo and Marco A. DeSousa.

In another move demonstrating the Defense Department’s commitment to renewable energy, the U.S. Navy recently announced that it intends to make its largest purchase of biofuels ever for a test run in 2012 of its “Great Green Fleet.” For several years the Navy, as well as other military branches, has been testing biofuels as an alternative to traditional fossil fuels. The Navy uses biofuels to power surface ships and aircraft.

The Defense Department is a major player in the renewable energy space, especially with respect to biofuels. Because of the Defense Department’s incredibly large appetite for energy, the Navy and other military branches have become market makers in the immature biofuels markets. Such large purchases provide much needed revenue to biofuel producers. The Navy has been as emphatic as any branch by setting a goal of procuring 50% of its energy from renewable sources by 2020.

The primary objective of the Navy’s progression towards renewable energy is national security. The security benefits of sourcing biofuels from domestic and diverse, non-domestic producers are obvious, but the profound effect on the economics of these developing markets is also a vested interest, and this is encouraging for renewable energy companies and for the broader goal of combating climate change. The large demand created by the Navy and other military branches for the physical delivery of biofuels is only one aspect of the influence these branches have on the biofuel markets. In addition to purchasing fuel from producers, the Navy has contracted with cutting-edge biotech companies in the R&D stage of production. It is clear that all companies in the biofuels space need to keep abreast of the Defense Department's biofuels development initiatives.

When so much talk about the federal government involves the perception, whether real or fictional, of its encroachment on the private sector, the Defense Department’s significant influence in the biofuels markets is a net positive for all Americans.

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This post was written by Sarah R. Wolff and Leonard E. Hudson.

The Department of Justice suffered a “stinging” setback to its widely touted FCPA Africa Sting prosecution late last week when the first of four anticipated trials based upon its most aggressive Foreign Corrupt Practices Act investigation to date ended in a mistrial. The jury deadlocked after six weeks of trial and after taking six votes while failing to reach a unanimous verdict in the bribery trial of four arms salesmen alleged to have offered to pay bribes to obtain military contracts.

In January, 2010, DOJ indicted 22 individuals, including citizens of the UK and Israel, claiming violations of the FCPA as a result of the defendants’ alleged payment of bribes to officials of Gabon in order to obtain government contracts to provide that country with armor, weapons and military gear. The indictments were brought following a lengthy FCPA undercover sting operation in which the purported foreign official to whom the defendants allegedly caused bribes to be paid was, in reality, an FBI agent as was a purported middleman to the alleged scheme. This was DOJ’s first large-scale undercover operation in connection with an FCPA investigation. The investigation is another example of the ongoing cooperation between U.S. and UK law enforcement agencies, particularly in the anti-corruption area. In this investigation, the FBI teamed up with the UK’s City of London Police. On January 18, 2010, the two agencies executed a total of 21 search warrants in various locations in the U.S. and in London.

Following the indictments, United States District Court Judge Richard Leon (District of Columbia) rejected DOJ’s request that he try all of the defendants together and broke them up into smaller groups for trial. At the close of the government’s case of four defendants in the first trial, the judge entered judgments of acquittal on some of the counts, with the most significant ruling coming on the motion of defendant Pankesh Patel, a UK citizen and the managing director of a UK company that acts as a sales agent for companies in the law enforcement and military products industries. Patel challenged a substantive FCPA count that rests upon a statutory jurisdictional requirement that a foreign defendant engage in corrupt activities “while in the territory of the United States.” DOJ has become increasingly aggressive in asserting jurisdiction over non-US residents based upon actions taken outside of the US as causing or aiding and abetting a corrupt or improper payment to be made. For example, the government has based FCPA charges against non-US citizens on conduct such as sending wire transfers requests from an account in a foreign country to a financial institution in the United States, and on sending emails and facsimiles from the UK to the US. Here, DOJ claimed jurisdiction over Patel in the count in question based on his sending a DHL courier package containing a purchase agreement in furtherance of the alleged corrupt scheme from the UK to the United States.

Patel moved for acquittal under the relevant count, arguing that he did not engage in any prohibited conduct “while in the territory of the United States” as required by the statute. In granting Patel’s motion, the judge expressed substantial skepticism regarding DOJ’s contention that sending a DHL package from the UK met the jurisdictional requirement, calling the theory a “novel interpretation” of the law. In granting the acquittal motion, Judge Leon said that “the more cautious, conservative interpretation would be that each act has to be while in the territory of the United States.” Judge Leon’s ruling is believed to be the first entered against the government on this jurisdictional ground and should encourage foreign defendants in other FCPA cases to test the limits of DOJ’s aggressive jurisdictional theories.

DOJ has announced that it will refile its case against the four defendants and will proceed with its case against the remaining defendants.
 

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This post was written by Christopher L. Rissetto and Robert Helland.

A flurry of legislative activity in the House of Representatives and Senate on measures affecting transportation infrastructure projects may signal movement on a multi-year spending in the 112th Congress. The need is clearly there: the American Society of Civil Engineers ("ASCE") in its 2009 "Report Card for America's Infrastructure", 33% of America's major roads were listed as being in poor or mediocre condition and 36% of the nation's major urban highways were congested. The ASCE gave our roads and bridges a grade of "D-". Our transit systems face a similar situation and only got a slightly better grade of "D". As any commuter will tell you, this situation has not improved.

The question is, how does the federal government pay to 1) maintain and 2) improve the nation's road and rail infrastructure with decreasing gas revenues flowing into the Highway Trust Fund (which is the main mechanism on the federal level to pay for such projects)? The answer may lie with fewer direct outlays of federal funds for transportation --compared to prior years-- and an increased reliance instead on the leveraging of funds, through the greater use of existing federal financing programs, the creation and capitalization of state "infrastructure banks" to provide financing for projects, and policies that will attract private sector investment i.e. through public-private partnerships. That's the emphasis in a transportation funding proposal released this week by the House Transportation and Infrastructure ("T&I") Committee Chair, John L. Mica (R-FL-7). The Public Policy and Infrastructure Practice takes a look at what is being proposed and how likely any measure will be enacted into law, given the nation's fiscal situation.

Leveraging is a key component in the SAFETEA-LU reauthorization proposals from the House Transportation and Infrastructure Committee.
At issue is the re-authorization of the multi-year transportation law known as "SAFETEA-LU" which provides funds for road and rail programs and projects. The law should have been re-authorized before its September 30, 2009 expiration, however, decreasing revenues into the Highway Trust Fund, which is funded primarily by the tax on motor fuels, has resulted in an impasse on any decision for new law. Instead the existing law has been subject to a series of temporary extensions, the latest expiring on September 30th of this year. A sign that this could change occurred this week when House T&I Chairman Mica introduced a six year, $230 billion SAFETEA-LU re-authorization proposal. This is over $50 billion less than the $286.5 billion included in SAFETEA-LU when it was signed into law in 2005. (Public Law-109-59) In a recent press conference and PowerPoint presentation, Chairman Mica detailed three tools to help stretch this lower dollar figure further: 1) He authorizes $6 billion to fund the Transportation Infrastructure Finance and Innovation Act ("TIFEA") program. TIFEA provides low interest loans, loan guarantees and lines of credit "to finance surface transportation projects of national and regional significance". According to the Chairman, this would fund at least $120 billion in transportation projects. 2) Chairman Mica would authorize and capitalize “State Infrastructure Banks” to provide loans and loan guarantees for state and local transportation projects. States would be able to dedicate 15% of the formula funds received under SAFETEA-LU to help do this. 3) Chairman Mica would encourage private sector investment in transportation. He would do so by increasing the use of financing programs, such as TIFEA, which fund projects with private-sector funding. He would also encourage public-private partnerships for transportation projects by providing greater credit towards a “local share” of a project’s cost to those that utilize such partnerships. In addition, he would remove barriers that he says prevents the private sector from offering public transportation services.

We note that Congressman Mica’s Senate counterpart, Senate Environment and Public Works Chair Barbara Boxer (D-CA) proposed her own version of a SAFETEA-LU re-authorization bill and has criticized Congressman Mica’s bill as inadequate for the nation’s transportation needs. Her bill would provide a greater amount of annual funding but over less time ($109 billion over two years). Whether both the House and Senate can agree upon a figure will depend on whether the pent-up demand by state and local governments and the business community for a steady stream of transportation funds will overcome any concerns about the cost to the federal purse. However, it is probable if not definite that any measure that reaches the President’s desk will include a financing mechanism for transportation projects

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This post was written by Nick Tyler.

The closure of the News of the World, the best-read Sunday newspaper in the English language, is a stark illustration of the reputational and commercial damage that can result from privacy-intrusive practices carried out in the name of ‘investigative journalism’.

The UK’s phone-hacking scandal, which has been rumbling for years, blew up this week after it came to light that it was not just public figures and celebrities that were targeted but ordinary people (and their families) who were the victims of crime, terrorism and war. Such egregious and unconscionable behaviour saw an advertising boycott by companies which will result in the last edition of the newspaper this Sunday carry no commercial advertising.

Ultimately, for the newspaper’s owner Rupert Murdoch, the reputational price proved too high as the scandal’s effect threatens the share price of News Corporation International as well as their multi-billion pound takeover of BSkyB in the face of universal public outrage.

As the criminal investigation finally gets into gear, with arrests of high-profile figures expected and a public inquiry ordered by the Prime Minister, it is worth noting that the UK’s data protection regulator, the Information Commissioner Christopher Graham, this week reminded everyone that over five years ago his office (the ICO) first brought to light the unlawful trade in personal information with two special reports to Parliament, What Price Privacy?’ and ‘What Price Privacy Now?’ .

When first publishing these reports the ICO pressed for the strongest possible sanctions for those found guilty of the most serious criminal offences under UK data protection law. Those representations resulted in a power to change the law (see section 77 of the Criminal Justice and Immigration Act 2008). This power would enable the penalty for breaches of section 55 of the Data Protection Act 1998 to include custodial sentences. However, it has not yet been exercised by the UK Government.

On the back of the latest scandal the Commissioner this week called for that power to be exercised. We can expect that call to become stronger and louder over the coming weeks and months.

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This post was written by Rosanne Kay and Tom Webley.

The Financial Services Authority (“FSA”) recently announced its intention to carry out a thematic investigation of the policies and procedures that investment banks have in place to prevent their staff and agents from paying or receiving bribes. Click here for the full speech.

This coincides with the coming into force of the Bribery Act 2010 on 1 July 2011. Click here for more information about the Bribery Act.

Thematic reviews are carried out by the FSA to look into widespread issues affecting a whole industry, market or product and result in the publication of a report of what the FSA discover. Although they may lead to enforcement action against specific firms depending on what the FSA find, the reviews are not enforcement actions in themselves.

A similar review was carried out of the insurance sector which resulted in the publication of a report in June 2010 highlighting a widespread lack of understanding of the risks of corruption and compensation and bonus schemes which increased the risks of bribery.

In their recent announcement, the FSA highlighted the overlap between corruption and money laundering. Indeed, most banks will already have detailed procedures in place to reduce the risk of failing to comply with, for example, anti-money laundering rules as well financial sanctions and FCPA requirements. They may well therefore have most of the relevant procedures in place to deal with bribery risks already
 

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This post was written by Leslie A. Monahan.

A proposed rule issued by the Department of Defense, the General Services Administration, and the National Aeronautics and Space Administration on June 28, 2011 proposes to amend the Federal Acquisition Regulation (“FAR”) to provide a single set of standards for contract officers reviewing contractor past performance. In 2010, agencies were required to transition their various information systems for storing performance reviews into the Contractor Performance Assessment Reporting System (“CPARS”), which would serve as a single performance feeder system governmentwide. Now, regulators seeks to continue implementing streamlining procedures by standardizing the evaluation factors and rating scales in past performance reviews.

The proposed changes stem from a 2009 Government Accountability Office report on the need for better performance information in making contract award decisions. The basis for the proposed rule also gained momentum with the issuance of an Office of Federal Procurement Policy memorandum concerning strategies for improving the assessment of contractor past performance.

Under the proposed rule, regulators plan to implement a five-point scale to standardize the contractor past performance evaluation process. In particular, contractors will be evaluated based on rating definitions found in CPARS guidance that range from exceptional to unsatisfactory. All evaluations are intended be tailored to the contract type, size, content, and complexity of contractual requirements.

According to regulators, while the proposed rule may be new, it only intends to codify in the FAR existing guidelines and practices, Further, the proposed language for the amended FAR provisions is language already used by Federal agencies. Contractors interested in commenting on the proposed rule must submit their comments by August 29, 2011.
 

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This post was written by Cynthia O’Donoghue and Nick Tyler.

The UK Minister responsible for government policy on data protection has raised concerns about any proposed “radical rewrite” of the EU Data Protection Directive.

Kenneth Clarke, Lord Chancellor and Secretary of State for Justice, called for both flexibility and a common-sense solution to modernising data protection law. He recognised that “technology has moved on” and that future EU regulation of data protection must address the “broader landscape” without getting caught up in “endless” debate “over the details”.

The flagging at this stage of some fundamental UK opposition to a number of specific reforms does not bode well for a happy consensus emerging from the EU-wide negotiations to follow the hotly anticipated publication of the EU Commission proposals:

What are seen as ‘Bad Ideas’?

• A new “right to be forgotten” – Worried about its impact on both business and the public, Mr Clarke made it plain that he wants the “right to be forgotten” to be forgotten!
• Revision of the Data Retention Directive – Mr Clarke staunchly defended the ability of law enforcement authorities across the world to collect, retain and pool data to improve security, in spite of concerns from privacy regulators and advocates.
• EU extra-territoriality – While acknowledging the aspirational “idea that European standards [of data protection] should apply to any firm processing EU citizens’ data anywhere in the world”, Mr Clarke was withering in his assessment that, on purely legal grounds, the European Commission must be “wrong”:

“I see little sign that the Commission has thought about this sufficiently yet. And how on earth are you going to enforce EU [data] protection on a global basis?”

Any ‘Good’ Ideas?

The Accountability Principle and Binding Corporate Rules –referring to the UK’s consultation on revision of the EU Data Protection Directive, Mr Clarke backed a more business-friendly solution:

“. . . [W]e should consider moving from a system which restricts information based on national standards of data protection, to a system based on the standard of data protection of the particular company involved – far more relevant to modern methods of business.”

Raising the Stakes for the Future of EU Data Protection?

The UK Government position appears against a move toward harmonization. In Mr Clarke’s view sticking to a set of shared principles and values, which at present has been implemented and is enforced in 27 different ways, would allow each country to be true to its own “constitutional and cultural identities”:

“. . . let’s learn to understand each other’s legal systems better, not rewrite our respective statutes and codes from scratch.”

This is a challenging prospect for global businesses trying to understand and comply with local law variations across Europe. They can only hope that the future EU data protection regime delivers some significant improvements to work with, and avoids the imposition of bad ideas in the form of arbitrary, additional and onerous obligations.
 

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The International Corporation for Assigned Names and Numbers (ICANN) announced last week that it has approved the plan for unlimited new gTLDs, and that ICANN will be taking applications from January 12 to April 12, 2012. The nightmare of many brand owners fearing that ICANN would adopt a system of unlimited gTLDs is now reality. Reed Smith hosted a teleseminar on June 28th to discuss how the gTLD program presents new burdens and obligations to brand owners and what organizations should be doing to protect themselves. To listen to the program, click here. To view a related client alert, ".anything On Its Way: New Generic Top Level Domains Will Launch January 12," released Monday June 20, click here.

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This post was written by Simon D. Hart.

With the coming into force of the UK's Bribery Act 2010 today, companies will be reviewing and revising a wide range of documents, policies and procedures across their organisation. Whilst in-house Counsel will almost certainly have been at the forefront of any internal review to ensure the company's readiness for the Bribery Act, the Human Resources department also has a very significant role to play in that exercise. Reed Smith's Employment group looks at the Act from an employment perspective.  To read more click here.

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