Anti-Bribery

News & Analysis as of

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

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

White Collar Crime Law Enforcement in a Trump Justice Department - 8 Predictions

After a conventional presidential campaign, determining the policy priorities and direction of the incoming administration with respect to the Justice Department’s white collar law enforcement responsibilities can be a...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

Top Ten International Anti-Corruption Developments for October 2016

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Recent Developments in Japanese Enforcement of Foreign Bribery Laws

In recent years, Japan has been under increasing scrutiny and pressure from the international community regarding its enforcement of its anti-corruption laws. A signatory to the OECD Anti-Bribery Convention, Japan enacted an...more

ISO 37001: Answers to the 5 Questions We’ve Heard Most About the Standard

It’s been a month since ISO 37001 was published and there are some questions we have heard percolating in the compliance world about what this means. These are the questions we’ve been hearing the most...more

A Cautionary Illustration of the Need for Accounting and Compliance Reviews

Embraer SA, Brazil's flagship aerospace manufacturer and a worldwide competitor across various aviation markets, experienced first-hand the scope and reach of the Foreign Corrupt Practices Act (FCPA). Embraer agreed to pay...more

ISO 37001: Why Your Anti-Corruption Policy Needs to Go Global

Ten years ago the standard anticorruption policy was nearly exclusively FCPA-focused. DOJ and SEC enforcement actions were the primary, if not the only, concern for corporate executives and board members. The UK Bribery Act...more

International Standards Organization issues certification standard for anti-bribery compliance systems

On October 15, 2016, the International Standards Organization Technical Committee ISO/PC 278 issued ISO 37001 titled, "Anti-bribery management systems - Requirements with guidance for use." ISO 37001(the Standard) "specifies...more

FCPA Enforcement Action Highlights Risks for the Financial Services Industry and Individual Executives

New York-based hedge fund Och-Ziff Capital Management Group (the “Hedge Fund”) agreed to pay approximately $412 million to resolve charges brought by the U.S. Securities and Exchange Commission (“SEC”) and Department of...more

A New Tool for Anti-Bribery Compliance Program: ISO 37001

Recently, the International Organization for Standardization (ISO) adopted a new set of standards, designated as ISO 37001, to assist organizations in their ongoing fight against bribery. As a result of recent increases in...more

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

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