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Corruption Enforcement Actions Risk Management

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements – Lesson No. 8, Enhancing Your Compliance Program

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Littler

Proper Planning and Swift Action Can Help Employers Avoid Foreign Corrupt Practices Act Prosecution

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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

American Conference Institute (ACI)

[Event] 12th Summit on Anti-Corruption Brazil - May 24th - 25th, Sao Paulo, SP, Brazil

Hosted by American Conference Institute, the 12th Summit on Anti-Corruption Brazil returns for another exciting year with a newly revamped, truly interactive networking and benchmarking experience. In addition to critical...more

American Conference Institute (ACI)

[Webinar] Anti-Corruption Brazil – FCPA Compliance and Enforcement in Brazil: DOJ and SEC Alumni Provide Critical Updates and the...

American Conference Institute’s expert faculty of DOJ and SEC alumni will update you with the most recent developments and risk factors confronting industry in Brazil and will lay out practical takeaways for satisfying the...more

American Conference Institute (ACI)

[Event] Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Hosted by American Conference Institute, the Mexico Summit on Anti-Corruption & Compliance Programs returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance...more

Oberheiden P.C.

Internal Audit for FCPA Compliance: A Detailed Guide

Oberheiden P.C. on

The Foreign Corrupt Practices Act (FCPA) (15 U.S.C. § 78dd-1 et seq.) is a federal anti-bribery law that makes it unlawful for certain people to pay foreign government officials in order to conduct business abroad. While it...more

The Volkov Law Group

Lessons Learned: Foster Wheeler FCPA Settlement Underscores Danger of Third-Party Risks (Part III of III)

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We all know and hear about third-party risks – over and over again. Despite this recurring theme, organizations continue to pay the price for failing to address third-party issues.  It does not take a rocket scientist to...more

The Volkov Law Group

Foster Wheeler FCPA Action: Dancing with the Devil – Risky Third Parties (Part II of III)

The Volkov Law Group on

FCPA settlement actions often underscore specific compliance risks for legal and compliance professionals. If there ever was a case where third-party risks were bungled, and even intentionally embraced, the Foster Wheeler...more

Thomas Fox - Compliance Evangelist

Cardinal Health FCPA Enforcement Action: High Risk Business Relationships

Cardinal Health Inc. (Cardinal) settled its Foreign Corrupt Practices Act (FCPA) matter with the Securities and Exchange Commission (SEC) last week. According to the SEC Press Release, Anita B. Bandy, Associate Director in...more

Morgan Lewis

UK Serious Fraud Office Emphasizes Importance of Compliance Programs

Morgan Lewis on

In a recent update to its internal guidance, the UK Serious Fraud Office provides insight into the general approach its investigators may take for evaluating organizations’ compliance programs—an approach similar to that of...more

Mitratech Holdings, Inc

Global Voices: Beating Bribery – Best Practice in Ethics and Conduct on the Global Stage

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

BCLP

Anti-Corruption Enforcement Webinar: 2018 in Review

BCLP on

Anti-Corruption enforcement remained a top priority in France, the UK, and the US in 2018. Join our firm's Global Anti-Corruption Team as they explain and analyze these three countries' anti-corruption enforcement efforts and...more

Thomas Fox - Compliance Evangelist

The Credit Suisse FCPA Enforcement Action: Part III – The Result and Going Forward

Last week Credit Suisse Group AG (CSAG) and Credit Suisse (Hong Kong) Limited (CSHK), a subsidiary of CSAFG, settled a Foreign Corrupt Practices Act (FCPA) enforcement action for just over $77 million for the illegal hiring...more

The Volkov Law Group

Textbook Lessons Learned from the Société Générale and Legg Mason FCPA Enforcement Action (Part III of III)

The Volkov Law Group on

Sometimes it takes a large enforcement action to underscore basic and important anti-corruption compliance principles. The Société Générale enforcement action demonstrated two important principles – the dangers of a weak...more

Thomas Fox - Compliance Evangelist

Responding to Investigative Findings

Most companies understand a the need for an investigative protocol or bringing in experienced investigative counsel should a substantive Foreign Corrupt Practices Act (FCPA) allegation arise. However what is not as well known...more

Thomas Fox - Compliance Evangelist

CCO Authority and Independence

Why is the focus on the CCO role now concerned with authority and independence? The role of the Chief Compliance Officer (CCO) has steadily grown in stature and prestige over the years....more

Thomas Fox - Compliance Evangelist

Using Strategic Risk to Your Advantage

I am beginning to feel this week’s theme becoming all-encompassing. As hard as I might try, it looks like it will be the Houston Astros second World Series appearance. During the first one back in 2005, I was in the corporate...more

Troutman Pepper

Long-Running Corruption Scheme Exposed in Brazil: Operation "Exposed Invoice" Provides Continuous Improvement Opportunity for...

Troutman Pepper on

A massive scheme involving medical products sales to Brazilian public entities has led to recent high-profile arrests. The events highlight the importance to a well-functioning compliance program of keeping up with new...more

The Volkov Law Group

The Real Explanation for the Record Year for FCPA Enforcement

The Volkov Law Group on

All the FCPA prognosticators, predictors and paparazzi have missed the boat on understanding what happened this year – 2016, to make this a record year in FCPA enforcement. As a former public servant for over 20 years, I am...more

Thomas Fox - Compliance Evangelist

Matt Ellis-The FCPA in Latin America

When I received my copy, my first thought was that, finally, it’s about time for this book to come out. Then I read it and realized I was glad he put so much time into it. I am referring to Matt Ellis’ new book The FCPA in...more

The Volkov Law Group

Trends from 2016 Record FCPA Enforcement Year (Part II of III)

The Volkov Law Group on

No matter how you cut it – this was a big year in FCPA enforcement. Not just because of the large enforcement actions but the scope and depth of enforcement, remediation and compliance program demands....more

The Volkov Law Group

Lessons Learned from Embraer $205 Million FCPA Settlement (Part II of II)

The Volkov Law Group on

The Embraer FCPA settlement action contains a number of important lessons learned and compliance reminders. In several significant respects, the Embraer case confirms in several areas why proactive compliance programs are...more

Thomas Fox - Compliance Evangelist

John Fogarty Rocks-Nu Skin Informs Oversight

I recently saw John Fogerty in concert. For those you are not aware, he was a founding member and the driving force behind Creedence Clearwater Revival (CCR), one of the very top American groups from the 1960s and early...more

Dechert LLP

Financial Services Quarterly Report - Second Quarter 2013: UK: New Regulators; New Powers

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The UK Financial Services Authority (“FSA”) was abolished on 1 April 2013 and replaced by three new regulators. The Financial Services Act 2012 introduced the Financial Conduct Authority (“FCA”), the Prudential Regulatory...more

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