沃尔玛只是美国公司海外行贿的冰山一角

    美国证监会近期提交的起诉书显示，摩根士丹利公司曾先后35次向公司房地产部董事总经理彼得森发出通知，提醒其遵守美国反腐败法，并特别说明，向中国上海市一家国有企业官员支付的款项违反了法律规定。然而，彼得森与该名中国官员仍私下瓜分了180万美元。此外，他还帮助自己与该官员与摩根士丹利达成一项非常优惠的协议，从后者那里购买了价值340万美元的资产。

    美国证监会执法部主任罗伯特•库赞尼表示：“彼得森曾两次违反法律规定。他曾秘密向一名政府官员行贿，为雇主招揽业务，并违反其对摩根士丹利客户的诚信义务，为自己谋取私利。该案件证明，美国证监会对于任何违反《反海外腐败法》的行为绝不姑息，尤其是那些故意规避公司内部控制的员工。”

    译者：阿龙/汪皓

    According to the recently filed suit by the SEC, Morgan Stanley gave its executive Peterson, a managing director in the company's real estate division, 35 different notifications reminding him of U.S. bribery laws, including specific instructions that payments to an official of a Chinese state-owned company in Shanghai would be against the law. Nonetheless, Peterson arranged to split $1.8 million in secret payments with the Chinese official. He also negotiated a sweetheart deal for himself and the Chinese official to purchase a $3.4 million property from a Morgan Stanley.

    "Peterson crossed the line not once, but twice. He secretly bribed a government official to illegally win business for his employer and enriched himself in violation of his fiduciary duty to Morgan Stanley's clients," said Robert Khuzami, Director of the SEC's Division of Enforcement. "This case illustrates the SEC's commitment to holding individuals accountable for FCPA violations, particularly employees who intentionally circumvent their company's internal controls."