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SEC Invokes Control Person Liability Provisions of the Exchange Act to Heighten Potential Exposure for FCPA Violations by Richard C. Smith
Fulbright & Jaworski L.L.P. - Washington Office
Marsha Z. Gerber
Fulbright & Jaworski L.L.P. - Houston Office
Carlos Rainer
Fulbright & Jaworski L.L.P. - Houston Office
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August 21, 2009
Recently, the U.S. Securities and Exchange Commission (the "Commission") filed a settled enforcement action involving charges brought by the Commission against Nature's Sunshine Products, Inc. ("NSP"), its Chief Executive Officer, Douglas Faggioli ("Faggioli"), and Chief Financial Officer, Craig D. Huff ("Huff"), alleging violations of the Foreign Corrupt Practices Act (the "FCPA"), 15 U.S.C. § 78dd-1. The charges concerned alleged bribery payments made by NSP's foreign subsidiary in Brazil in 2000 and 2001 to customs brokers in Brazil.
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