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Internal Controls Foreign Corrupt Practices Act (FCPA) Third-Party Risk

Thomas Fox - Compliance Evangelist

Operationalizing Compliance Through Payroll

One of the areas articulated in the 2023 ECCP was around payments and payroll. For the both the compliance professional and the corporate payroll function, there is a significant role to play in the operationalization of a...more

American Conference Institute (ACI)

[Event] 40th International Conference on the FCPA - November 28th - 30th, National Harbor, MD

Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...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

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

The Volkov Law Group on

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

American Conference Institute (ACI)

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - July 21st - 22nd, Boston, MA

ACI is excited to welcome you back in-person to the 14th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, taking place on July 21–22, 2022 in Boston! Legal and compliance professionals from...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

Foodman CPAs & Advisors

Instituciones Financieras y el FCPA

La Ley de Prácticas Corruptas en el Extranjero (“Foreign Corrupt Practices Act – FCPA”) prohíbe el pago de sobornos a funcionarios extranjeros para ayudar a obtener o retener negocios.  Exige que las empresas cuyos valores se...more

Foodman CPAs & Advisors

Financial Institutions and the FCPA

The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business.  It requires companies whose securities are listed in the US to maintain books and...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 5: Lessons Learned for the Compliance Professional

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 3: Internal Control Failures

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

The Volkov Law Group

Five Lessons for Third-Party Distributor Risk Management from Microsoft FCPA Settlement (Part III of III)

The Volkov Law Group on

The Microsoft FCPA settlement, while not significant in the total penalty of approximately $25 million, provides some important instructions concerning distributor and re-seller risks and mitigation strategies.  ...more

The Volkov Law Group

Lessons Learned from the Walmart FCPA Enforcement Action (Part III of III)

The Volkov Law Group on

This is a tough posting – frankly, there are so many lessons learned from the Walmart case that they could fill a book, or an e-book at least.  I will focus on some of the big issues....more

Thomas Fox - Compliance Evangelist

The Updated Evaluation of Corporate Compliance Programs – Guidance Document: Part 6 – Third Parties

We are in an exploration of the recently released Evaluation of Corporate Compliance Programs – Guidance Document(2019 Guidance), which was announced(ECI speech) by Assistant Attorney General Brian Benczkowski at the Ethics...more

The Volkov Law Group

The Important Link Between Anti-Corruption Compliance and Effective Training Programs

The Volkov Law Group on

Global anti-corruption risks are increasing at the same time that global cooperation among prosecutors and law enforcement agencies are facilitating the detection and penalization of companies and individual bad actors that...more

The Volkov Law Group

A Basic Compliance Requirement: A Contract Management System

The Volkov Law Group on

Lawyers love contracts. Most business people see the value of a contract and will comply with a requirement that a deal will require a contract in order to move forward. ...more

Jones Day

Anti-Corruption Regulation Survey of 41 Countries 2017–2018

Jones Day on

Welcome to the 2017-2018 edition of the Jones Day Anti-Corruption Regulation Survey. In 2017 and 2018 to date, there has continued to be an increasing awareness among multinational companies of the significance of...more

The Volkov Law Group

First FCPA Action of 2018: Elbit Imaging

The Volkov Law Group on

No one needs to be reminded about the importance of anti-corruption compliance. For global companies, anti-corruption risks are amongst the top 3 risks identified by corporate leaders....more

The Volkov Law Group

Financial Controls and Contract Management Systems

The Volkov Law Group on

Compliance officers understand that a company’s greatest risks surround access to and use of money. A CCO has to understand a company’s financial controls, and in a perfect world, should have a seat at the table in the...more

The Volkov Law Group

FCPA Recidivists: Zimmer Biomet (Part I of II)

The Volkov Law Group on

The drug and medical device industries have been taking it on the FCPA chin for years. The risk factors in the international marketplace are significant – healthcare professionals are normally government employees; government...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

Thomas Fox - Compliance Evangelist

Volkov on the Evolving Standards for Compliance Programs

Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...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

The Volkov Law Group

Building a Due Diligence Infrastructure (Part IV of IV)

The Volkov Law Group on

A due diligence infrastructure is designed to demonstrate a company’s good faith commitment to compliance with anti-corruption laws by: identifying corruption risks; and mitigating such risks to ensure that the company does...more

Thomas Fox - Compliance Evangelist

Germany in the World Cup and the Alstom FCPA Enforcement Action – Part II

“It was important that we played our game for 90 minutes.” That line was found in a The Daily Telegraph article entitled “The unthinkable scoreline: Brazil 1, Germany 7” by Jeremy Wilson. It was a quote from Mats Hummels,...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 91, Internal Controls for Third Parties Under the FCPA, Part II

In this episode, I continue my exploration of internal controls around third parties in a FCPA compliance program, with Henry Mixon. ...more

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