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Extradition Article - Procedures

Procedures of the UAE to deliver a suspect of Extradition - If there is a convention between UAE and another country for extradition, this will take priority to the UAE International Judicial Corporation Law, where...more

Anti-bribery compliance in India: Both sword and shield

In recent years, both the United States Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have stepped up their enforcement of the Foreign Corrupt Practices Act (FCPA), including to address...more

Red Notice Newsletter - November 2016

JPMorgan Resolves Enforcement Action Regarding China Subsidiary’s Hiring Practices - On November 17, 2016, JPMorgan Chase & Co. (JPMC) entered into a nonprosecution agreement with the Department of Justice (DOJ), and...more

Embraer’s FCPA Deferred Prosecution Agreement and $205 Million Payment Demonstrate Need for Adequate Internal Controls

Brazilian aircraft manufacturer Embraer SA (“Embraer”) will pay the United States government $205 million to settle allegations that the company violated the Foreign Corrupt Practices Act (“FCPA”) by paying millions in bribes...more

Sapin II Law: The Modernization of France's Fight Against Corruption

After years of facing international criticism for purported “laxity” towards transparency and the fight against bribery and corruption, France has adopted new legislation aiming to rectify this deficiency, which imposes...more

Extradition Article - Guidelines

Where the proposal has already been sent by the requesting party, Interpol will arrest the suspect and produce him to the Public Prosecution within 48 hours of his arrest. After the arrest, investigations are begun, the...more

Third-Party Risk Programs Should Focus on Offense, not Defense

Just 43 percent of organizations surveyed in NAVEX Global’s 2016 Ethics & Compliance Third Party Risk Management Report said they evaluated third parties before engaging with them—down from 68 percent in 2015....more

Still Serious About Sanctions: OFAC Settles Violations Involving Cuba and Iran

Lest U.S. companies think that Cuba and Iran are entirely open for business, a U.S. government settlement announced earlier this month with National Oilwell Varco, Inc. (NOV), a U.S. oilfield services company, will serve as a...more

Significant Swiss ruling handed down on privilege in anti-money laundering investigations

In a recent judgment, the Swiss Federal Tribunal has ruled that, where a financial institution delegates its investigation and reporting obligations under the Swiss Anti-Money Laundering Act ("AMLA") to external counsel,...more

Bridging the Week - November 2016 #3

Federal District Court Approves Flash Crash Spoofer’s US $38 Million Settlement; Federal Appeals Court Appears Sympathetic to Michael Coscia’s Claim That Spoofing Prohibition Is Too Vague - The US federal court handling...more

New Rule: The Fight Against Corruption Speaks French

On November 8, France adopted its new framework legislation against corruption, the Law on Transparency, the Fight against Corruption and Modernization of Economic Life, otherwise called the “Sapin II Law” from the name of...more

Beneath A Panamanian Moon: Criminalising Secrecy

Originally published in Risk Advisory, 2016. The term “Panama Papers” has become a by-word for financial skulduggery. On 3 April 2016, the International Consortium of Investigative Journalists revealed that it had a...more

Corruption Risk in Pharma and Medical Device Markets [Video]

At the 17th Annual Pharmaceutical and Medical Device Compliance Congress (October 2016, Washington DC), Paul Hastings Partner Gary Giampetruzzi and I exchange perspectives on a panel titled "Behind the Bribe: Multiple Real...more

Everything Compliance-Episode 2 [Video]

This episode is dedicated exclusively to where FCPA enforcement, SEC enforcement, the compliance profession and compliance programs may be headed under the Trump administration, with a dash of anti-trust enforcement and EU...more

What you should know about identity theft

Take precautions in giving your personal information as people with ill intentions may misuse it. Dubai: As alarming as it sounds, you could be the next victim of identity theft.The phenomenon is becoming more prevalent...more

FCPA and Jail - Are Corporate Officers Really at Risk?

On Oct. 31, James McClung, a former Louis Berger International Inc. executive, self-surrendered to the Bureau of Prisons to begin his year-and-a-day sentence for violations of the Foreign Corrupt Practices Act (FCPA)....more

Sales Incentives: How To Tame This Potential Ethical Foe [Video]

In this fast-moving 15-minute video, I exchange perspectives with Kristy Grant-Hart, CEO of Spark Compliance Consulting, on one of the most potent problems of our time: sales incentives gone amuck. From the Wells Fargo...more

Gym members shocked as Fitness First installs CCTV cameras in changing rooms

DUBAI // The operator of a gymnasium chain has installed security cameras in changing areas, sparking anger from members and warnings that it could be breaking the law. Customers of Fitness First Middle East’s gym...more

How Trump’s First 100 Day Plan Effects Immigration

President-elect Donald Trump has released his “100-Day Action Plan to Make America Great Again.” Unsurprisingly, the plan includes many policies that will impact immigration. Immigration was one of the biggest issues raised...more

Follow the money - the Criminal Finances Bill

The Criminal Finances Bill sets out measures to combat money laundering and tax evasion that will also affect corporate compliance requirements, particularly in the finance and professional services sectors....more

Criminal Law - Fraud

Federal Law No.(3) For the Year 1987 on Passing Penal Code Article No.399: "Shall be punishable by confinement or by a fine any individual who, by using fraudulent practice, assuming a false name or quality, takes...more

Red Notice Newsletter - October 2016

ANTICORRUPTION DEVELOPMENTS – DOJ Issues First-Ever Declinations Requiring Disgorgement of Profits to Resolve FCPA Violations - On September 29, 2016, the Department of Justice (DOJ) for the first time announced...more

Corporate Corruption, Culture and Compliance (Part II) [Video]

In part II of my interview on CCTV America, The Heat (October 25th), I respond to questions about the hazards which can occur when compliance leaders lose their “line of sight” into the business. I also share my...more

Directors’ Duties in the UK (England and Wales)

A director who breaches the obligations and duties imposed on him by his office may be liable to compensate the company for breach of duty, may incur personal liability for the company’s debts, may also face criminal or civil...more

Corporate Corruption, Culture and Compliance (Part I) [Video]

On October 25th, I appeared on CCTV America, The Heat, where I took a deep dive into the issue of corporate corruption in the United States. My co-panelists were Marc Hodak, who counsels corporations as the Founder of...more

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