Episode 344 -- SEC Settles FCPA Case with Moog for $1.7 Million
Episode 343 -- TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations
Episode 342 -- How to Conduct an Internal Compliance Site Visit and Review
Extraterritoriality — RICO Report Podcast
Fintech Focus Podcast | Sanctions Compliance: Regulators Set Their Sights on Fintechs
Sanctions Compliance: Regulators Set Their Sights on Fintechs
The Presumption of Innocence Podcast: Episode 47 - Fireside Chat With Bill Baroni and Jesse Eisinger
Episode 340: DOJ Updates Evaluation of Corporate Compliance Programs
Public-Private Partnerships to Stem Corruption
Navigating Compliance in Government Contracts: Insights from SEC and DOJ Perspectives
Episode 339: Four Sanctions Cases Everyone Should Know
Episode 338 -- Deep Dive into the Deere SEC FCPA Case
INTERPOL Red Notices - do they expire?
The Legal Tightrope: Surviving Parallel Investigations
Navigating Government Contracts: Diana Shaw on Oversight and Whistleblower Protections
The Presumption of Innocence Podcast: Episode 45 - The Grit, Grace and Gift of Second Chances
Wicked Coin: The "Fat Leonard" Scandal
Should you try to remove an INTERPOL Red Notice yourself?
Episode 335 -- The New DOJ Whistleblower Program
Navigating Civil Standing Requirements for Defense Success — RICO Report Podcast
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
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
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
What have we learned from 2020? I think all of us have learned quite a bit in both our personal and professional lives. 2020 has stretched us as individuals and as organizations in various and unexpected ways. ...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
You could begin with the Transparency International-Corruption Perception Index (TI-CPI) to garner a sense of the reputation of the country in which your business unit is located, as well as the CPI for all other countries in...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
Most experts agree that whichever regulatory jurisdiction an organisation is subject to, there are five common fundamentals involved in providing effective corporate compliance....more
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
Growing Chinese illicit finance threats, vulnerabilities, and exposure are combining to increase illicit financing risk in the international financial system, judging from a series of recent advisories, sanctions actions,...more
I have long predicted that corporate board members are in for a rude awakening. Corporate boards have to improve their ability and knowledge surrounding supervision and monitoring of a company’s ethics and compliance...more
In my showcase of profound but obvious points, let me add to my collection – an illegal bribe often turns on the actor’s state of mind. Did he or she act with corrupt intent?...more
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
NAVEX Global recently released an important compliance report – 2019 Definitive Corporate Compliance Benchmarking Report. NAVEX’s report contains a number of interesting findings and brings together several current...more
If businesses were to understand that if they engage in bribery and corruption, the impact is much larger than simply the bribe they pay for the business opportunity. It can literally ruin the lives of many more people....more
Bribery and corruption have long plagued the construction industry, particularly in emerging markets in Latin America, Eastern Europe, the Middle East and Asia-Pacific. ...more
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
Corporate bribery requires money. How is that for something obvious. Companies face a variety of threats – one enduring threat is the risk of fraud or theft. Unfortunately, employee fraud is all too common. ...more
According to Samuel Rubenfeld, reporting in the Wall Street Journal (WSJ) Risk & Compliance Journal, “Treasury Secretary Steven Mnuchin told lawmakers that he wants to make corporate ownership information available to law...more
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
Corporate commitment to speak up cultures is suffering. The Ethics and Compliance Initiative’s recent Global National Business Ethics Survey contained a critical finding – corporate instances of retaliation against employee...more
I have finished up my week in Brazil and I wanted to end this week’s Brazil focused blog posts with some final thoughts and observations on the country’s burgeoning compliance scene....more
It's been almost seven years since the UK Bribery Act (the Act) came into force. The Act's reach is extra-territorial but on the Act's home soil, on 21 February 2018, we saw the first contested case of "adequate procedures." ...more