Episode 343 -- TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations
Leadership Lessons From The West Wing — Hiring to Firing Podcast
Episode 342 -- How to Conduct an Internal Compliance Site Visit and Review
Wicked Coin: FIFA: Soccer, Scandal, and Sportswashing
The Presumption of Innocence Podcast: Episode 47 - Fireside Chat With Bill Baroni and Jesse Eisinger
Public-Private Partnerships to Stem Corruption
Why Privacy is Your Secret Weapon Against Third-Party Risk
Due Diligence in AI: 3 things you need to survive AI scrutiny
Episode 337 -- Nicolas Garcia, GC at Orica, on Compliance Trends and Challenges in Latin America
Navigating Government Contracts: Diana Shaw on Oversight and Whistleblower Protections
A Third Party's Perspective on Third Party Risk
Cannabis Law Now Podcast: Cannabis Companies and the Corporate Transparency Act
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
Episode 329 -- Bryn Sedlacek from Aravo on TPRM Holistic Risks and Unified Visibility
Episode 328 -- Sanctions Enforcement Risks and Redlines
Managing Corruption Risk in Latin America
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
Examining FinCEN FAQs, Proposed Legislation and Other CTA Developments
Episode 320 -- NAVEX Hotline Report -- More Reports and Higher Substantiation
The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the Justice Department Fails to Prosecute Executives'
We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more
In March 2024, the Department of Justice (DOJ) announced the resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international...more
We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm Gunvor S.A. The enforcement action came in with a $661 million penalty against the company, which has pleaded...more
While 2023 was a relatively slow year in FCPA enforcement, the DOJ and SEC settlements announced throughout the year set out a list of important ethics and compliance reminders. While these may seem obvious to everyone, I...more
2023 was a very significant year for every compliance practitioner and compliance program. While there was a paucity of corporate enforcement actions under the Foreign Corrupt Practices Act (FCPA), there were significant...more
UN Corruption Convention’s Ratification - In October 2003, the General Assembly officially ratified the United Nations Convention against Corruption (“Corruption Convention”). Since that time, a total of 190 countries have...more
While the Department of Justice (DOJ) has initiated at least two new Foreign Corrupt Practices Act (FCPA) enforcement actions against U.S. companies, it has also announced several decisions not to prosecute—most recently...more
Survey: Tech gaps, third parties pose biggest ABAC threats - Compliance professionals surveyed regarding their anti-bribery and corruption efforts (ABAC) indicated resource support deficiencies in areas including staffing...more
Here are some basic propositions that surround FCPA compliance. It is often underplayed that the FCPA contains more than just a bribery prohibition – the FCPA contains broad provisions, requiring accurate books and records...more
In the FCPA and white collar defense community, we have seen buckets and buckets of ink spilled on the coming wave of aggressive enforcement. Justice Department officials have made so many statements about the “new” approach...more
Even with the absence of any major DOJ FCPA enforcement actions, DOJ issued an interesting FCPA Opinion Letter last week addressing application of the FCPA in circumstances where organizations face imminent serious bodily...more
You could begin with the Transparency International-Corruption Perception Index (TI-CPI) to garner a sense of the reputation of the country in which your business unit is located, as well as the CPI for all other countries in...more
On July 3, the Criminal Division of the U.S. Department of Justice (“DOJ”), and the Enforcement Division of the U.S. Securities and Exchange Commission (“SEC”) released an updated joint Resource Guide to the U.S. Foreign...more
On July 3, 2020, the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) updated their 2012 joint guidance on the Foreign Corrupt Practices Act (“FCPA”) in the SEC and DOJ’s FCPA Resource Guide...more
Last week, the Department of Justice (DOJ), without fanfare, released an update to its 2019 Evaluation of Corporate Compliance Programs, the 2019 Guidance. For simplicity this new document will be called the 2020 Update. ...more
One of the lessons we have learned from various Foreign Corrupt Practices Act (FCPA) enforcement actions over the years is how complexity in business organizations can work to defeat compliance programs. ...more
The Department of Justice recently announced updates to its Foreign Corrupt Practices Act Corporate Enforcement Policy. While the changes were relatively minor, the modifications underscored important principles surrounding...more
The original version of the FCPA, enacted in 1977, contained an exception for payments made to non-U.S. officials who performed duties that were “essentially ministerial or clerical”. In 1988 Congress responded by amending...more
I am in a multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand and implement some of the key concepts of the Framework into your...more
The drumbeat of those supporting ISO 37001 continues. However, I still find it to be misplaced as anything close to the international standard for anti-bribery/anti-corruption programs....more
This episode 30 is Part 2 of my interview with the FCPA Professor. ...more