Public-Private Partnerships to Stem Corruption
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
INTERPOL Red Notices and Immigration. Can You Obtain Immigration Relief in the U.S. Even with a Red Notice?
Why Time Matters: Partners Lindsay Gerdes and Michael J. Bronson on Swift Action in Government Investigations
The Presumption of Innocence Podcast: Episode 43 - New Horizons: Impact of Recent Appellate Circuit Rulings on White-Collar Criminal Defense Law
INTERPOL and Politically Motivated Red Notices - What We Can Learn from INTERPOL’s Annual Reports.
Episode 333 -- The Boeing Proposed Plea Agreement
The Presumption of Innocence Podcast: Episode 41 - The Dynamics of Decision-Making: Psychology and the Criminal Justice System
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
What to do when finding that you are the subject of a RedNotice?
Episode 324 -- Third-Party Risks and Sanctions Compliance
It may seem like a Herculean task — but it can be done. I regularly opine that mitigating sanctions risks for your third-party population is an easier task than doing so for your anti-corruption risks. One big reason —...more
The various and elusive tactics used by Russia to evade global sanctions and export controls have grown increasingly sophisticated over the last several months, putting the onus on multinational entities to become equally...more
Hosted by American Conference Institute, the 11th Annual Advanced Forum on False Claims and Qui Tam Enforcement returns for another exciting year for lively discussions on FCA enforcement including the ramifications of two...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
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
As companies move forward on third-party risk management programs, and as automated third-party risk solutions are being implemented, compliance professionals have to re-examine and re-balance the allocation of resources and...more
With a new year, many folks have been promoted to the CCO chair. What should be your plan starting the new year and a new job. The answer is found in the eBook Compliance Program Game Plan by myself and Jonathan Marks. ...more
On Monday, December 16, we begin with Episode IV-A New Hope and management of risk. We use Grand Moff Tarkin’s incorrect assessment that the risk presented by the Rebellion’s final attack on the Death Star was non-lethal. I...more
On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...more
Welcome to the 2019 edition of the Jones Day Anti-Corruption Regulation Survey of Select Countries. Since the 2017–2018 edition of this Survey, there has continued to be an increasing awareness among multinational companies...more
How important is due diligence on those with whom you are doing business? Why does it matter if a company is owned or controlled by a foreign government or a political party member of a foreign government? ...more
If you want to learn and read about managing third-party risks, you will have no trouble finding articles, white papers, webinars and more available to you on the Internet. And for good reason....more
I break due diligence down into three stages: Level I, Level II and Level III. Candice Tal, Founder and Chief Executive Officer (CEO) of Infortal Worldwide, in an article entitled “Deep Level Due Diligence: What You Need to...more
In Part IV of my series on ISO 37001, I examine requirements relating to risk assessments, design of policies and procedures, and due diligence requirements. Section 4.5 sets out requirements for conducting risk...more
Identifying Bribery and Corruption risk in the context of private equity investments (and M&A more generally) is key to ensuring the value of an acquisition. Companies will busy themselves with due diligence on tax,...more
2016 was a banner year for global anti-corruption enforcement: the U.S. government set records in terms of both the number of FCPA actions brought and the total dollar amount of related fines. Meanwhile, governments from...more
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
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
If you review the last ten years of FCPA enforcement, the unmistakable pattern is rising expectations with regard to corporate compliance programs, particularly with regard to third party due diligence and risk management....more
I find myself quibbling with compliance terms – hyper focus on small issues is not a positive trait. I often urge clients and colleagues to focus on issue of more significance and leave the smaller ones for another day....more
Our Focus on Private Equity provides a global perspective on some of the challenges being faced by PE firms and how these can be successfully addressed. It also examines some of the many opportunities available, e.g., by...more