Wicked Coin: FIFA: Soccer, Scandal, and Sportswashing
Episode 339: Four Sanctions Cases Everyone Should Know
Episode 338 -- Deep Dive into the Deere SEC FCPA Case
FCPA Survival Guide - Step 8 - Investing in Compliance
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
Compliance Tip of the Day – Compliance Lessons from the Albemarle FCPA Enforcement Action
FCPA Survival Guide: Step 1 - Self-Disclosure
All Things Investigations: Compliance Lessons from Gunvor and Trafigura Enforcement Actions
Corruption, Crime & Compliance: Deep Dive into The Trafigura FCPA Settlement
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
Compliance into The Weeds: Trafigura FCPA Enforcement Action
Corruption, Crime & Compliance: Deep Dive into The Gunvor FCPA Settlement
Episode 314 -- A Deep Dive into Gunvor's FCPA Settlement
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 311 -- Tom Fox on FCPA Enforcement: Self Disclosure and Recidivism
Episode 307 -- Sanctions Enforcement Review and Predictions for 2024
The risks for international investments have sharply expanded in recent years. Identifying, managing, and mitigating investment risk, in the current regulatory environment, can be just as essential as managing risk in any...more
The roar of the crowd, clinking champagne flutes, and gourmet cuisine… it’s the Big Game, and the season of extravagant corporate hospitality packages is in full swing. Welcome to the high-stakes minefield of conflicts of...more
Earlier this month at the ACI Mexico Summit on Anti-Corruption & Compliance, Foreign Corrupt Practices Act (FCPA) and compliance lawyers from across Latin America gathered in Mexico City for two days of thought leadership and...more
ACI’s Mexico Summit on Anti-Corruption & Compliance Programs returns on March 13-14, 2024 in Mexico City! Given the uncertainty with the looming Presidential election, as well as increased U.S. enforcement focus on Mexico...more
One of the key goals of any compliance program is to train employees in awareness and understanding of the FCPA; your specific company compliance program; and to create and foster a culture of compliance. While it seems...more
Mr D Thompson v Informatica Software Ltd- In a recent appeal at the EAT an individual (the “appellant”), who had been a senior employee of the employer (ISL), was found to have been fairly dismissed for gross misconduct...more
Recent developments include updated DOJ compliance guidance, a continued rise in FCPA proceedings and penalties, and new investigatory approaches in light of the pandemic. 2020 saw many important developments in US white...more
- A tone-at-the-top business culture with CEO leadership is a critical component of effective anti-corruption and anti-bribery policy implementation. - CEO leadership helps set an example for lower management and company...more
The Covid-19 Pandemic and the accompanying reduction in economic activity has been a rationale for Financial Institutions (FI) to re-analyze their budgets for compliance training and education. FIs, as well as businesses in...more
On April 30, 2019, Assistant Attorney General Brian Benczkowski unveiled an update to the Department of Justice’s Evaluation of Corporate Compliance Programs during a speech in Dallas, Texas.[i] In issuing the new document...more
Global anti-corruption risks are increasing at the same time that global cooperation among prosecutors and law enforcement agencies are facilitating the detection and penalization of companies and individual bad actors that...more
On March 8, 2019, the U.S. Department of Justice announced an important change to its Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy concerning one of the conditions — “appropriate retention of business...more
One of the key lessons I learned in doing the research for The Complete Compliance Handbook is the evolution of compliance programs beyond the basic formulation laid out in the 2012 FCPA Guidance’s Ten Hallmarks of an...more
Hunter S. Thompson once said that when the going gets weird, the weird turn pro. It turns out that amateurs can get weird too. The University of Mississippi football program, which is under a self-imposed postseason ban and...more
The global chaos unleashed by the WannaCry ransomware virus reinforces that cyberattacks are not just the problem of IT departments. Compliance must play an integral part of any organization’s cross-functional cybersecurity...more
DOJ’s Compliance Evaluation questions provide important indications of “new” trends and approaches to compliance functions and issues. Training - In the area of training, DOJ’s Compliance Evaluation reiterates DOJ’s...more
In a recent Slate article, entitled “Ethics Trainings Are Even Dumber Than You Think”, author L.V. Anderson railed against what she termed box-checking training where companies put on training not to actually train employees...more
Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more
Tammy Grimes died earlier this week. For those of you not familiar with that name, you may well know the name of the Broadway musical which catapulted her to fame, The Unsinkable Molly Brown. Grimes garnered a Toni in 1960...more
Battered by the rise of online shopping, cybersecurity and bruised by changing consumer patterns, retailers today must cope with a host of new headwinds—heightening the risks of compliance failures in a business that’s...more
In a remarkable affirmation of the value of robust compliance and due-diligence programs, the Securities and Exchange Commission last month announced that it would not prosecute a U.S. company for potential violations of the...more
I. Training - The communication of your anti-corruption compliance program is something that must be done on a regular basis to ensure its effectiveness. The FCPA Guidance explains, “Compliance policies cannot work...more
The next time we read about a train wreck of corporate malfeasance – be it in the anti-corruption, money laundering, financial reporting or any other space you can think of – please do not shrug your shoulders and shake your...more
I continue to explore innovation in the compliance function by considering how design thinking can help the Chief Compliance Officer (CCO) move forward in an innovative cutting edge manner to make a compliance program not...more
This week, I am exploring issues related to compliance and ethics training, inspired by an article in the online publication, Slate, entitled “Ethics Trainings Are Even Dumber Than You Think”, by author L.V. Anderson. Today I...more