Compliance into the Weeds: Understanding the Telefonica Venezuela FCPA Enforcement Action
Episode 344 -- SEC Settles FCPA Case with Moog for $1.7 Million
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
Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more
Sorry to start a four-part series with a reference to music from our long-ago past. The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965). So, how does that relate to third-party risks? Well,...more
We continue our exploration of corporate culture. Today, we consider the intersection of the Fraud Triangle and a toxic culture. The Fraud Triangle is well-known to most compliance practitioners. It is pressure, opportunity,...more
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
The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the life cycle management of third parties, most compliance practitioners understand the need for a...more
One cannot really say enough about risk assessments in the context of anti-corruption programs. This is because every corporate compliance program should be based on a risk assessment, on an understanding of your...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
Over the past several blog posts, I have been exploring the Albemarle FCPA enforcement action. We have explored in some detail the DOJ Non-Prosecution Agreement (NPA) and the SEC Administrative Order(Order). In this final...more
Compliance professionals are always looking for ways to collaborate and support internal business partners. Through the years, compliance professionals have devoted significant energy to building partnerships with the...more
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
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
While my first posting highlighted the positive developments in the CCO’s role and professional development, the next two postings present troubling concerns....more
In 2020, the Justice Department did not insist on the appointment of any independent compliance monitors. The year before, in 2019, DOJ insisted on the appointment of three independent corporate monitors – MTS...more
White collar practitioners Neil Smith, William Semins, Nicole Stockey, and David Peet discuss their key takeaways from this year’s 37th International Conference on the Foreign Corrupt Practices Act....more
The Coronavirus health crisis has wrought many changes in the business world and corporate compliance. Over the next few blog posts, I want to explore in some depth what I see are the key changes for the Chief Compliance...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
Yesterday, I wrote about the Cardinal Health, Inc. Foreign Corrupt Practices Act (FCPA) resolution with the Securities and Exchange Commission (SEC). One of the areas that many compliance practitioners confuse is evaluating...more
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
The Houston Astros sign-stealing scandal is only going to get worse and worse. In addition to the report by Wall Street Journal (WSJ) of the “Dark Arts” program by the Astros front office to steal signs in a program called...more
As most compliance practitioners know, the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs, 2019 Guidance, concentrated focus on culture in a way the DOJ has not done previously. This concentrated...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
The Department Of Justice (DOJ) and Securities and Exchange Commission (SEC) have both made it clear that they expect companies to be more robust in their use of data analytics in compliance programs....more
How should a compliance professional think about managing risk? How about senior management? Even the Board of Directors is being called upon more and more to manage risk from its oversight perspective. I recently revisited a...more
By using risk-based monitoring, you can begin to see things in “almost real-time, time-based trends of real data that you can then jump on and try to make adjustments before things get really wacky.” The implications to the...more