I remain amazed at the consistently-high estimates of the percentages of U.S. companies doing business internationally, which do not have FCPA and related anti-corruption policies and programs. Beyond the obvious and...more
When I first read about the changes to the United States Department of Justice’s official guidance on its long-standing “Evaluation of Corporate Compliance Programs,” I immediately set out to identify, digest, and analyze...more
In 2015, then-Deputy AG Sally Yates (Attorney General Eric Holder’s second-in-command) published DOJ’s new policy statement on the investigation and prosecution of corporate offenses, heavily increasing focus on individuals...more
Previously we introduced you to the FCPA and provided updates about the positive international trends in anti-corruption legislation; efforts to punish and deter bribery; the Organization for Economic Cooperation and...more
1/17/2020
/ Acquisitions ,
Anti-Bribery ,
Anti-Corruption ,
Chief Compliance Officers ,
Civil Liability ,
Compliance ,
Corruption ,
Criminal Penalties ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
Mergers ,
OECD ,
Ratings ,
Risk Management ,
Transparency International ,
Whistleblowers ,
White Collar Crimes
This article, which will be published in three parts, provides a compact overview of recent developments and emerging trends in international anti-corruption laws and compliance programs.
For the last several years, I and...more