News & Analysis as of

Gearing Compliance to the Tasks at Hand

I recently had the opportunity to travel to Chicago for my first SCCE Compliance and Ethics Institute (CEI), and attended a session “Keeping Compliance Simple,” which was led by Ricardo Pellafone, CEO, The Broadcat...more

G20 Anti-Corruption Action Plan 2017-2018 Published

The G20 published its Anti-Corruption Action Plan for 2017-2018 and called on countries to implement the United Nations Convention against Corruption. The G20 established the Anti-Corruption Working Group in 2010, a body...more

How Can We Develop Anti-Bribery Ambassadors? [Video]

In this interview with Frank Brown, Value-Chain/Anti-Corruption Program Team Leader at the Center for International Private Enterprise (CIPE) we exchange perspectives on a number of issues, including: * How can we get...more

Tribute to Star Trek and Anti-Corruption Compliance Programs

September 8th is the 50th anniversary of the premier episode of the most iconic science fiction related television show during my lifetime – Star Trek. As most of you know, I am a self-confessed uber-trekkie and I can still...more

Australian Companies Face Greater Scrutiny With New Foreign Bribery Investigations Team

On 5 September 2016, the Commonwealth Government announced the establishment of a Perth-based specialised fraud and anti-corruption team that will focus on foreign bribery investigations. Justice Minister Michael Keenan has...more

Don't be fooled - Australian anti-bribery and corruption laws exist

Australian companies and their employees shouldn't think, based on recent press reports, that Australia doesn't already have serious anti-bribery and corruption laws. Australia's anti-bribery and corruption laws apply both...more

Japan Bar Association Issues New Anticorruption Compliance Guidelines

On July 15, 2016, the Japan Federation of Bar Associations (JFBA) issued new guidance for companies on complying with Japanese and other foreign anti-bribery laws (the “Guidance”). The Guidance comes on the heels of and...more

Hallmark 4- Risk Assessments

One cannot really say enough about risk assessments in the context of anti-corruption programs. Since at least 1999 the DOJ has said that risk assessments that measure the likelihood and severity of possible Foreign Corrupt...more

"China and the Foreign Corrupt Practices Act"

Recent U.S. Department of Justice (DOJ) policies on corporate crime prosecutions, coupled with the Chinese government’s robust anti-corruption campaign, are proving challenging for U.S. corporations with business operations...more

U.S. Targets Private Equity Funds for FCPA Scrutiny

The private equity industry is facing increased scrutiny by the U.S. Government for potential violations of the Foreign Corrupt Practices Act (“FCPA”). The Securities and Exchange Commission (“SEC”) has created a new private...more

Corporate Investigations and White Collar Defense - June 2016

Eye on the Supreme Court—Corruption and Fraud Edition - Why it matters: This session, the Supreme Court has undertaken the review of numerous cases that raise thorny issues arising in the white collar context. In our...more

Arrested Development: Fighting fraud & corruption in international aid

The following interview is with Oliver May. RB: Oliver, you’ve been specialising in how corruption affects aid organisations. Perhaps you could tell us a little about your background and how you got into that? OM:...more

France Considers New Anti-Corruption Authority

France has introduced a draft bill which proposes to establish a new anti-corruption authority, which will have the power to impose administrative sanctions and conduct US-style monitoring of companies’ anti-bribery...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

Joe Spinelli on the Kroll-Ethisphere Anti-Bribery & Corruption Report [Video]

In part one of a two-part series, Joe Spinelli, Senior Managing Director at Kroll in the Investigations and Disputes Practice, addresses a number of findings as referenced in the Kroll-Ethisphere “The Year of Global...more

The New Italian Public Procurement Code

The Italian Council of Ministers approved a new Legislative Decree reforming the Italian Public Procurement regulation, implementing Directives 2014/23/EU, 2014/24/EU and 2014/24/EU. On April 18, 2016, the Italian...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

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

French Anti-Corruption Reform Expected In 2016

France to introduce significant changes affecting large companies and top management, to improve current anti-bribery system. The French Parliament is expected to enact “Sapin II” on transparency, anti-corruption and...more

Tackling Market Abuse And Corruption — Finally

In the next few weeks, the French Minister of Finance should present to the Government a Bill which would, if adopted, reform the French regime on market abuse, create a new anti-corruption agency and impose an obligation on...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

New DOJ Guidance and FCPA Pilot Program, Part I-Introduction

Last week the Department of Justice (DOJ) held a Press Conference, open to all, led by Andrew Weissmann and Leslie Caldwell. At this Press Conference, they announced the culmination of several ongoing initiatives into a new...more

Anti-Bribery: Lessons From The First Deferred Prosecution Agreement — Between The SFO And A Bank

The Serious Fraud Office’s recent deferred prosecution agreement with Standard Bank, the first in the UK, provides a useful walk through the new legislation, but a more complex case is needed to shine some light on the...more

Parent Company and Subsidiary Liability for FCPA Violations: Fighting the Disinformation Campaign

Akin to politics (to a smaller degree), there is a fair amount of disinformation, some call it bloviating, put out by the FCPA Paparazzi. Some of this disinformation is motivated by immature attempts to “market” legal...more

New Books And Records Offences Strengthen Australia’s Anti-Bribery Regime

New criminal offences concerning false dealing with accounting documents have been introduced into Australia’s Commonwealth Criminal Code (Criminal Code). The changes address Australia’s obligations under the OECD Foreign...more

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