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Ransomware: How to Avoid It and What to Do If You Have Been Hit

Computer systems around the world have been impacted by the largest cyber-extortion attack in history. According to news reports, the “ransomware” attack hit more than 200,000 victims in 150 countries since it started on...more

Palm Oil Supply Chain Abuses Reported by Amnesty International: Steps to Mitigate Legal Risk

Amnesty International recently released a report alleging that supply chains for production of palm oil—a common ingredient in many consumer products—are tainted by forced and child labor. In the nearly 150-page report titled...more

Don’t Let Forced Labor and Bribery in Your Supply Chain Spoil the Holidays

The holiday retail season is an ideal time to check that forced labor and bribery—two top and interconnected supply-chain threats—do not undermine the success of your critical sales period. Not long ago, many in the...more

New Law Increases Scrutiny for Importing Goods Made with Forced Labor

The federal government took another step in the fight against human trafficking and forced labor. President Obama signed into law on February 24, 2016, the Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA), which...more

France’s Foreign Public Corruption Law (Article 435-3)

The chart traces the flow and logic of Article 435-3 (proscribing foreign corruption), discusses the Government’s 2015 anti-corruption “Compliance Guidelines,” and summarizes the pending anti-corruption...more

Doing Business in the U.K.? Modern Slavery Act £36M Threshold Issued

Companies doing business in the United Kingdom take note: the U.K. government just made the not-so-long-awaited announcement that businesses with an annual turnover of 36 million British pounds (£36M) will be subject to the...more

Groundbreaking Change to Rules for Federal Contractors Aims to Stamp Out Human Trafficking Up and Down the Supply Chain

Companies that contract with the federal government will soon be subject to new rules aimed to stamp out human trafficking (see discussion of some of the existing rules and regulations here and here). The just-released...more

Mutual Legal Assistance Treaties And Letters Rogatory: A Guide For Judges

The investigation of transnational criminal conduct often involves gathering evidence located in foreign countries. However, national sovereignty, international treaties, and international law preclude U.S. law enforcement...more

Germany's Foreign Anti-Corruption Efforts: Second-Tier No More

A March 2011 report by the Organization for Economic Cooperation and Development’s (OECD’s) Working Group on Bribery characterized Germany as assuming a “leading position” in the investigation and prosecution of foreign...more

4/10/2014  /  Anti-Corruption , Bribery , EU , OECD

Regrouping And Refocusing: 2013 FCPA Year-In-Review And Enforcement Trends For 2014

Following a relatively flat enforcement landscape and some bumps in the 2013 prosecutorial road, the Department of Justice (‘‘DOJ’’) and the Securities and Exchange Commission (‘‘SEC’’) appear poised to spring back into...more

The Compliance Crystal Ball—Top 10 Compliance Trends For 2014

It is that time of year again when we dust off the compliance crystal ball and take a look at what might be in store for 2014. 1. Executive Order 13627 Changes Government Contracting - Want a government contract...more

Top 10 Compliance Trends For 2014

As 2013 wraps up, it is that time of year again when we dust off the compliance crystal ball and take a look at what might be in store for 2014: 1. Executive Order 13627 on Trafficking in Government Contracts —...more

Investigating Alleged Board Member Misconduct

Let us start our discussion with an area of broad consensus: A company’s board of directors has a duty of care to respond to and investigate allegations of wrongdoing by officers and employees of the company. But what happens...more

Navigant Investigations Quarterly 2013 - The Next Compliance Deluge: Understanding Foreign States’ Mandatory Corporate Social...

Corporate Social Responsibility (CSR) has evolved from a “nice idea” or “marketing opportunity” to a true business imperative. Companies are increasingly becoming sophisticated with respect to CSR reporting and are checking...more

Weighing The Price Of Crime — Apportioning Restitution Based On Relative Fault

Criminal justice practitioners understand that ‘‘joint and several liability’’ stands for the common proposition that each co-conspirator should be equally responsible for all provable losses the conspiracy caused. Put...more

Planning For When Things Go Wrong: Are You Ready To Investigate Allegations Of Board Member Misconduct?

Let us start our discussion with an area of broad consensus: A company’s board of directors has a duty of care to respond to and investigate allegations of wrongdoing by officers and/or employees of the company. But what...more

Perils Of The Global Supply Chain Series, Part 3: Groundbreaking ‘Honey Laundering’ Sting Signals New Era In Supply Chain...

Supply chain compliance is on the government’s enforcement radar like never before. If the recent Executive Order on Trafficking in Government Contracts and final SEC Conflict Minerals Rules were not notice enough, the...more

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