Wicked Coin: The "Fat Leonard" Scandal
Corruption, Crime & Compliance: Deep Dive into The Gunvor FCPA Settlement
Episode 307 -- Sanctions Enforcement Review and Predictions for 2024
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
Episode 296 -- Deep Dive into Clear Channels SEC Settlement of FCPA Violations
Episode 294 -- Catch Up on OFAC Enforcement: 3M and Emigrant Bank
The Maritime Anti-Corruption Network: An In-Depth Conversation
Season 2 - Episode 2 - A Whistleblowers Nightmare: The Uncovering of the 1Malaysia Development Berhad Scandal
The Justice Insiders Podcast: Varsity Blues Reversals Turn DOJ Red
Corruption, Crime, and Compliance - The Ericsson FCPA DPA Breach Settlement
Episode 258 -- Deep Dive into ABB FCPA Settlement
Corruption Crime & Compliance - Deep Dive into the ABB FCPA Case
Life with GDPR - The ABB Enforcement Action from a UK Perspective
The Corruption Files - Episode 15 - The ABB Settlement
The Line Between Gift Giving and Bribery
The Corruption Files - Episode 14 - Walmart with Tom Fox and Michael DeBernardis
Compliance Into The Weeds - Lafarge and the Cost of Moral Bankruptcy
The New Cold War: Risk, Sanctions, Compliance Episode 21: "Interview with Drago Kos of the OECD Working Group on Bribery"
The Justice Insiders: FIFA Corruption Trial – Will the Feds Score Another Goal?
The Presumption of Innocence Podcast: Episode 5 - Doing Business Overseas: The Foreign Corrupt Practices Act
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
Regulators and enforcement authorities in Australia intensified their efforts to curb white-collar crime in 2023. They targeted fraud, money laundering, tax evasion, cybercrime, and corruption across multiple industries,...more
Commercial bribery enforcement also became more active, as the authorities marked the 30th anniversary of the PRC Anti-Unfair Competition Law. The revision of the PRC Anti-Espionage Law raised some concerns about national...more
The Department of Justice has been relatively quiet this year in bringing corporate FCPA enforcement actions and settlements. Aside from the Ericsson breach of its Deferred Prosecution Agreement, the Corficocolombiana...more
Over the course of the year — and even dating back to his time on the campaign trail — President Biden and senior officials in his administration, including Department of Justice (DOJ) and Security and Exchange Commission...more
On June 3, 2021, the White House issued a National Security Memorandum, in which President Biden identified countering corruption as a “core” U.S. national security interest. The President directed the Assistant to the...more
What have we learned from 2020? I think all of us have learned quite a bit in both our personal and professional lives. 2020 has stretched us as individuals and as organizations in various and unexpected ways. ...more
Getting to grips with the "new normal" needn't be guess work or a pursuit of the clairvoyant. While much remains uncertain, understanding how anti bribery and corruption (ABC) issues will develop in 2021 need not be. We have...more
In this third edition of October HorrorFest 2020 celebration we consider the first Hammer film sequel (and second in the series) – The Revenge of Frankenstein which was released in 1958. It begins as the Curse of Frankenstein...more
On 31 August 2020, the Australian Law Reform Commission's Final Report on Corporate Criminal Responsibility was tabled in Parliament. The Final Report makes significant recommendations for reform of corporate criminal...more
En 1977, los Estados Unidos promulgó la Ley de Prácticas Corruptas en el Extranjero (FCPA). El FCPA prohíbe una oferta, pago, promesa o la autorización de un pago de dinero o cualquier cosa de valor (también conocido como...more
In 1977, the United States enacted the Foreign Corrupt Practices Act (FCPA). The FCPA prohibits an offer, payment, promise or the authorization of a payment of money or anything of value (a/k/a bribery) to a foreign official...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
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 Situation: At the direction of the Attorney General of Australia, the Australian Law Reform Commission ("ALRC") is undertaking a comprehensive review of Australia's Commonwealth corporate criminal liability regime. The...more
I have long predicted that corporate board members are in for a rude awakening. Corporate boards have to improve their ability and knowledge surrounding supervision and monitoring of a company’s ethics and compliance...more
One of the biggest headaches for companies conducting business overseas still remains bribery and corruption. The grey area of what is deemed a fair gift, meal or payment against what might be constituted a bribe is a...more
NAVEX Global recently released an important compliance report – 2019 Definitive Corporate Compliance Benchmarking Report. NAVEX’s report contains a number of interesting findings and brings together several current...more
If businesses were to understand that if they engage in bribery and corruption, the impact is much larger than simply the bribe they pay for the business opportunity. It can literally ruin the lives of many more people....more
This year is the 200thanniversary of the birth of Wuthering Heights’ author, Emily Brontë. While her sister Charlotte received more acclaim as an author, I found Wuthering Heights to appeal much more greatly to my dark side. ...more
I have finished up my week in Brazil and I wanted to end this week’s Brazil focused blog posts with some final thoughts and observations on the country’s burgeoning compliance scene....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
In my final posting on ISO 37001, I review requirements for training, raising concerns and internal investigations as part of a company’s anti-bribery risk management system....more
In Part IV of my series on ISO 37001, I examine requirements relating to risk assessments, design of policies and procedures, and due diligence requirements. Section 4.5 sets out requirements for conducting risk...more
In Part III of my continuing series on ISO 37001, today I examine the board and top management’s respective responsibilities in the implementation and oversight of an anti-bribery management system....more