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Internal Controls Bribery Compliance

The Volkov Law Group

John Deere Reaches $9.9 Million Settlement with SEC over FCPA Violations

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The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the...more

Womble Bond Dickinson

Navigating the Labyrinth: Artificial Intelligence in the Battle Against Trade-Based Money Laundering

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In the rapidly evolving financial landscape, governments worldwide are intensifying their focus on compliance in Know Your Customer (KYC) and Anti-Money Laundering (AML) efforts for financial institutions. Trade-Based Money...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2023

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Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 4 – Internal Control Failures

Albemarle Corporation (Albemarle), recently agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more

Bradley Arant Boult Cummings LLP

Philips Agrees to Pay $62M to Settle FCPA Books-and-Records Violations from Efforts to Win Chinese Contracts

Koninklijke Philips N.V., a global medical technology manufacturer, recently agreed to pay over $62 million to resolve a Foreign Corrupt Practices Act (FCPA) enforcement action with the Securities and Exchange Commission...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

The Volkov Law Group

The Importance of Accounting and Internal Controls (Part I of II)

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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

The Volkov Law Group

Digging into the ABB Bribery Details in South Africa (Part II of III)

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The details of bribery schemes are invaluable for learning how criminals think – bribery always requires some scheme to transfer money from the organization to fund bribery payments to a government official(s).  Compliance...more

Thomas Fox - Compliance Evangelist

Oracle: FCPA Recidivist Part 5 – What Does It All Mean?

In this post, we conclude our exploration of the Foreign Corrupt Practices Act (FCPA) enforcement action involving the now recidivist Oracle Corporation. This enforcement action was concluded with the Securities and Exchange...more

The Volkov Law Group

Oracle’s FCPA Violations: A Lesson in Managing Third-Party Distributor Risks (Part II of II)

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Oracle’s SEC settlement for $23 million underscores the power of the FCPA provisions mandating effective internal controls and accurate books and records.  As everyone knows, these provisions can be applied to a wide-range of...more

The Volkov Law Group

GOL’s Bribery Schemes Orchestrated by Board Director (Part II of II)

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GOL’s bribery schemes present some interesting lessons.  Interestingly, at the center of the bribery scheme was a member of GOL’s board of directors.  The bribery scheme was motivated by potential legislation that would...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - July 11th - 14th, Singapore, Singapore

Are you looking to better… - Support, enhance, and manage a compliance and ethics program? - Mitigate risk within your organization? - Understand the components of effective program infrastructure? SCCE’s Basic...more

Morgan Lewis

Due Diligence, Ethics, and Compliance Considerations for Dealmakers

Morgan Lewis on

In recent years, the US Department of Justice (DOJ) and US Securities & Exchange Commission (SEC) have further defined their anti-corruption due diligence and disclosure expectations of acquiring companies pre- and...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - June 20th - 23rd, Amsterdam, Netherlands

Are you looking to better… - Support, enhance, and manage a compliance and ethics program? - Mitigate risk within your organization? - Understand the components of effective program infrastructure? SCCE’s Basic...more

Society of Corporate Compliance and Ethics...

[Virtual Event] ESG and Compliance Conference - April 26th, 7:55 am - 3:15 pm CDT

Discover how to set and accomplish your ESG goals - Environment, Social, and Governance (ESG) is no longer an isolated function within a company, nor is it an issue only for publicly traded companies. It’s front and...more

American Conference Institute (ACI)

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

Join the Go-To Event of the Year for Mexico’s Anti-Corruption Community. The annual ACI’s Anti-Corruption Summit in Mexico is back to Mexico City on March 22-23, 2022! This is the most important anti-corruption compliance...more

Thomas Fox - Compliance Evangelist

Internal Controls Week: Part 5-Assessing Internal Controls in International Operations

How should you assess your internal controls regime for international operations? It is incumbent that you need to review as much information as you can to understand the financial and operational structure of an entity and...more

Thomas Fox - Compliance Evangelist

Internal Controls in Compliance: Part 3-Key Compliance Internal Controls

There are four significant controls that I would suggest the compliance practitioner implement initially. They are: 1) DOA; 2) maintenance of the vendor master file; 3) contracts with third parties; and 4) movement of...more

Thomas Fox - Compliance Evangelist

Internal Controls in Compliance: Part 2-Rigor In Your Internal Controls

New York Times columnist David Brooks’ thoughts on building and maintaining order inform the discussion on rigor in your internal controls. In internal controls, I believe it is incumbent to consider not only the most obvious...more

Thomas Fox - Compliance Evangelist

Internal Controls in Compliance: Part 1-What are Internal Controls?

What specifically are internal controls in a compliance program? Internal controls are not only the foundation of a company but are also the foundation of any effective anti-corruption compliance program. The starting point...more

The Volkov Law Group

WPP SEC FCPA Enforcement Action: Lessons Learned (Part III of III)

The Volkov Law Group on

The SEC’s FCPA enforcement action against WPP presents a number of important lessons learned, ranging from third-party risk management, properly responding to employee complaints and red flags, and failure to integrate...more

Latham & Watkins LLP

Japanese Ministry of Economy, Trade and Industry Updates Guidance to Prevent Foreign Bribery

Latham & Watkins LLP on

Companies with business operations in Japan should review due diligence procedures and internal policy regarding small facilitation payments to ensure they are consistent with new guidance from METI. In May 2021, the...more

The Volkov Law Group

Deutsche Bank FCPA and Fraud “Spoofing” Settlement: A Review of Deutsche Bank Conduct (Part II of II)

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Deutsche Bank’s ethics and compliance function faces numerous challenges.  Deutsche Bank has a storied record of scandals, government enforcement actions and failures to abide by prior deferred prosecution agreements (DPAs)....more

Thomas Fox - Compliance Evangelist

Deutsche Bank – FCPA Recidivist: Part 3 – Overlooked Red Flags and Internal Control Failures

Last week, according to a Department of Justice (DOJ) Press Release, Deutsche Bank Aktiengesellschaft (DB), “agreed to pay more than $130 million to resolve the government’s investigation into violations of the Foreign...more

The Volkov Law Group

Beam Suntory Bribery Scheme: Another Controls Failure (Part II of II)

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The Beam Suntory case is yet another example of a failure of internal and external auditors, and legal and compliance professionals.  Reviewing cases involves a focus on how and why a compliance failure occurred....more

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