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UK Bribery Act – 5 lessons in 5 years: No. 3 – Incentivising Self-Reporting

Bribery by its very nature is generally a secret matter. Self-reporting is therefore a useful tool by which the SFO can learn of, and take action against, wrongdoing. But what are the incentives for a company to self-report?...more

UK Bribery Act – 5 lessons in 5 years: No 2 – Unheard Voices

The corporate bribery offence has brought in a new age of enforcement, but at what cost to individuals who may be implicated? In the last few weeks of 2015, the enforcement landscape for corporate entities carrying on...more

DOJ Announces First Declinations After Implementing FCPA Pilot Program

The U.S. Department of Justice (DOJ) issued its first set of public declinations since its April unveiling of a new self-reporting Foreign Corrupt Practices Act (FCPA) pilot program. On June 7, 2016, Akamai Technologies,...more

UK Bribery Act – 5 lessons in 5 years

Love it or loathe it, the Bribery Act has put anti-corruption compliance on the boardroom agenda like nothing has done before. More than just ‘box ticking’- When the Bribery Act was introduced into the UK in 2011,...more

A COSO Look at Control Objectives

Brian Christensen, in an article in Corporate Compliance Insights (CCI) entitled “The Updated COSO Framework: Time for a Fresh Look at Internal Control”, said that the updated 2013 COSO Framework retained the core definition...more

Want to Work in Compliance – Learn How to Read a Balance Sheet

One of the most interesting tag lines I heard at Compliance Week 2016 was the following, if you want to work in my compliance department; you need to learn how to read a balance sheet. I thought that single line encapsulated...more

Red Notice Newsletter - May 2016

ANTICORRUPTION DEVELOPMENTS - Former Securency Manager Convicted of Corruption - On May 11, 2016, Peter Michael Chapman, former manager of polymer banknote manufacturer Securency PTY Ltd. (“Securency”), was...more

Joe Spinelli on Corruption Risk & FCPA Due Diligence [Video]

In part II of our interview, Joe Spinelli, Senior Managing Director, Kroll, addresses a number of issues which were shared in the Kroll-Ethisphere 2016 Anti-Bribery and Corruption Benchmarking Report. In this interview, Joe...more

ISO 37001: A New Measuring Stick for Corporate Compliance Programs

The International Organization for Standardization is developing a certifiable international standard for “anti-bribery management systems” that could influence how the US Department of Justice, US Securities and Exchange...more

The Pen is Mightier than the Compliance Sword

Nicole Rose brings a breath of fresh air to compliance. 6 years ago she swapped her legal practicing certificate for her pen and has been thriving ever since. She founded Create Training almost 3 years ago, and over this...more

10 Takeaways from Deputy Attorney General Sally Q. Yates’ Remarks at the 2016 New York City Bar Association White Collar Crime...

This week, Deputy Attorney General Sally Q. Yates delivered remarks at the New York City Bar Association reflecting on the eight months since the release of the “Yates Memo,” or as Deputy AG Yates prefers, the “Individual...more

FCPA (and my) Failure

I haven’t thought too much about failure lately, until I read Roy Snell’s piece, “We Are All Victims…Except Richard Bistrong.” Roy’s article took me by surprise, as his blog piece addresses a primary foundation of my work:...more

DOJ Announces Pilot Program for Self-Reporting FCPA Misconduct

In an effort to move forward with the Department of Justice's (DOJ) policy of individual responsibility, the agency announced a pilot program to encourage corporations to self-report Foreign Corrupt Practices Act (FCPA)...more

English court compels investigators to disclose information on data protection grounds

The High Court has ruled that a company conducting an investigation may be compelled to give effect to requests for information made under data protection legislation. The case serves as a stark reminder that data protection...more

Panama Papers Scandal Puts Third Party Risk in Focus

The Panama Papers scandal should serve as a wake-up call for every organization—and it should prompt compliance officers to closely scrutinize the third party vendors they do business with. ...more

Shakespeare Week – Part III: Much Ado About Nothing and Incorporation of Social Media into Your Compliance Program

How does Shakespeare portend social media in the 21st century? I would submit that one only need look at Much Ado About Nothing to see how it should all play out. As with all Shakespeare’s plays there is quite a bit going on...more

Compliance 2.0: DOJ Pushes the Compliance Agenda

The FCPA Paparazzi have a thick head and a stubborn chin. They just do not understand the significance of Compliance 2.0 to corporate governance and they blindly adhere to simplistic, yet unexplained, solutions to complex...more

New US Department of Justice Foreign Corrupt Practices Act Enforcement Plan Creates "Pilot Program" to Encourage Voluntary...

The U.S. Department of Justice (“DOJ”) released a memorandum (the “FCPA Enforcement Memorandum”) on April 5, 2016 detailing a new enforcement plan for Foreign Corrupt Practices Act (“FCPA”) investigations. The DOJ announced...more

"DOJ Adds Resources for FCPA Cases, Offers Incentives for Voluntary Disclosures"

On April 5, 2016, the Department of Justice’s (DOJ) Fraud Section made two related announcements in its Foreign Corrupt Practices Act (FCPA) Enforcement Plan and Guidance. First, the Fraud Section announced a substantial...more

Foreign Financial Institutions Beware: United States Expands Economic Sanctions Against Hizballah

Effective April 16, 2016, the United States will implement sanctions pursuant to the Hizballah International Financing Prevention Act of 2015. The new sanctions target Hizballah (or Hezbollah) and non-U.S. persons who support...more

DOJ Launches FCPA Pilot Program to Promote Company Self-Reporting

In a speech delivered last Wednesday by Assistant Attorney General Leslie Caldwell, the Justice Department’s (“DOJ”) Criminal Division announced the launch of a new Foreign Corrupt Practices Act (“FCPA”) “pilot program” that...more

Anti-Bribery and Compliance Challenges Ahead [Video]

In this short video, Richard Fenning, CEO, Control Risks, shares his reflections on the 2016 Control Risks “International Business Attitudes To Corruption Survey” which is available on the Control Risks website. In the...more

Key Findings from NAVEX Global's Third Party Risk Management Benchmark Report

Vendor risk management and, in particular, third party risk management has become one of the toughest issues companies face—especially after a string of high-profile compliance failures in recent years. The majority of...more

Bridging the Week - March 2016 #4

Alleged Spoofer, Blamed for Partly Causing Flash Crash, Loses UK Extradition Hearing - Navinder Sarao, the London-based futures trader who in April 2015 was sued by the Commodity Futures Trading Commission and criminally...more

Australia Raises its Anti-bribery Compliance & Enforcement Game

After broad international and domestic criticism of its efforts, the Australian Government is now showing an appetite for significant reform in the area of foreign bribery....more

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