News & Analysis as of

Third-Party Risk Bribery Foreign Corrupt Practices Act (FCPA)

The Volkov Law Group

“The New FCPA”: The Future Landscape of Sanctions Enforcement (Part II of IV)

The Volkov Law Group on

We are all familiar with — over and over — third-party risks and FCPA risks. It is drilled in our collective heads — third-party risks and bribery. Legal and compliance professionals have to learn and understand the ins...more

The Volkov Law Group

The Same Old Song with a Different Meaning — Third-Party Risks and Sanctions Compliance (Part I of IV)

The Volkov Law Group on

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

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - May 13th - 16th, 9:00 am - 3:00 pm CT

SCCE’s four-day Compliance & Ethics Essentials Workshop provides comprehensive education on the core elements of a compliance program in a convenient virtual format. The curriculum is ideal for those new to or with little...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - December 4th - 7th, 9:00 am - 3:30 pm CT

SCCE’s four-day Compliance & Ethics Essentials Workshop provides comprehensive education on the core elements of a compliance program. The curriculum is ideal for those new to or with little experience in compliance, as well...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - October 16th - 19th, 11:55 am - 6:30 pm CET

SCCE’s four-day Compliance & Ethics Essentials Workshop provides comprehensive education on the core elements of a compliance program. The curriculum is ideal for those new to or with little experience in compliance, as well...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - September 18th - 21st, 9:00 am - 2:30 pm CT

SCCE’s four-day Compliance & Ethics Essentials Workshop provides comprehensive education on the core elements of a compliance program. The curriculum is ideal for those new to or with little experience in compliance, as well...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - May 15th - 18th, 8:55 am - 3:30 pm CT

SCCE’s four-day Compliance & Ethics Essentials Workshop provides comprehensive education on the core elements of a compliance program. The curriculum is ideal for those new to or with little experience in compliance, as well...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

The Volkov Law Group

Lessons Learned from the KT Corp. SEC FCPA Settlement (Part III of III)

The Volkov Law Group on

Even though the size of the KT Corp. SEC enforcement action is relatively small, the underlying misconduct provides a number of important lessons learned. ...more

The Volkov Law Group

Keeping Track of Third Party Risks – Bribery and Sanctions

The Volkov Law Group on

We have heard it over and over, again and again – third-parties pose significant risks of bribery for all global businesses.  Almost every FCPA enforcement action includes some form of third-party misconduct.  The current...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - December 6th - 9th, 8:55 am - 2:30 pm CST

SCCE’s Compliance & Ethics Essentials Workshop provides a comprehensive introduction to the elements of a compliance program to enable attendees to be a more effective member of the compliance team. The workshop is ideal for...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

The Volkov Law Group

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

The Volkov Law Group on

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

American Conference Institute (ACI)

[Event] Anti-Corruption London - November 2nd - 3rd, London, United Kingdom

C5's 15th International Conference on Anti-Corruption London will take place November 2 – 3, 2021 in Millennium Hotel London Knightsbridge, London. Join your peers for the IN-PERSON reunion of the legal and compliance...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

The Volkov Law Group

Letting Third Parties Do the Dirty Work

The Volkov Law Group on

We all know it when we see it – a recurring fact pattern in which a company enlists a corrupt third party intermediary for one purpose (and one purpose only) – to pay a bribe.  Let me give you a few examples....more

Holland & Knight LLP

Lessons Learned from the Airbus Anti-Corruption Settlements

Holland & Knight LLP on

In late January 2020, Airbus agreed to pay nearly $4 billion and to take a number of remedial measures in order to resolve alleged corruption violations with the French National Financial Prosecutor's Office (PNF), the United...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 4: The Double Whammy in Penalties

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

Ericsson’s Pervasive Bribery Conduct: The Toxic Mix of Senior Executive Involvement and Third Party Corruption (Part II of II)

The Volkov Law Group on

Ericsson’s FCPA settlement is in the books (not the books and records).  But it casts a significant shadow across the FCPA landscape.  A pervasive and systemic culture of bribery is defined to reflect senior executive...more

The Volkov Law Group

Managing High-Risk Distributor Risks (Part I of II)

The Volkov Law Group on

Companies will often rely on a network of distributors to help sell their products in emerging markets.  From a business economics standpoint, engaging a distributor is often more cost efficient than investing in a sales...more

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