News & Analysis as of

Third Parties and the Red Flags You Don’t See

Recently, I was reading a White Paper by Dun and Bradstreet titled “Anti-Bribery and Corruption Compliance for Third Parties: Is an off the shelf product enough?”. As the D&B paper points out, “the risks of insufficient...more

Benchmarking Bribery and Corruption: "Vet it and forget it."

On my own "must read" stack has been sitting the "2014 Anti-Bribery and Corruption Benchmarking Report, Untangling the Web of Risk and Compliance," ("ABC Report") by Kroll and Compliance Week. While I have read a multitude...more

FCPA Compliance and Ethics Report-Episode 76-World Cup Report-Part VI [Video]

In this episode, which is the first of a two part series, Mike Brown and I begin to wrap up some of our thoughts and take-aways from the recent World Cup. We discuss anti-bribery and anti-corruption in the context of the...more

Kroll Anti-Bribery & Corruption Benchmarking Report: 58% of Organizations Give No Anti-Bribery Training to Third Party Vendors?!

Another one of my favorite sessions at Compliance Week featured Lonnie Keene from Kroll and Matt Kelly of Compliance Week presenting the 2014 Anti-Bribery and Corruption Benchmarking Report. It’s a very thorough report and...more

Building a Next-Generation Anti-Bribery & Corruption Compliance Program

Global companies face unprecedented third party risk in today’s landscape — third parties are involved in 90% of Foreign Corrupt Practices Act (FCPA) cases, and more companies are under investigation than ever before in the...more

Maybellene And The 2014 Anti-Bribery And Corruption Benchmarking Report

Today, we celebrate an event, which is not ‘the day the music died’ but one that might properly be called one of the seminal moments in the creation of Rock N’ Roll. On this date in 1955, Chuck Berry recorded his first song,...more

The FCPA Compliance and Ethics Report-Episode 66, Visit with Virna De Palma from TRACE [Video]

In this episode I visit with Virna De Palma,Senior Director, Global Strategy & Communications at TRACE International, Inc.. She talks about some of the services which TRACE offers and details a new and exciting scholarship...more

FCA Fines Besso Limited for Anti-Bribery and Corruption Systems Failings

The Financial Conduct Authority (FCA) has fined Besso Limited, an independent management owned general insurance broker in the Lloyd’s Broking group, £315,000 for a failure to take reasonable care to establish and maintain...more

3 Basic Steps to Improving the Effectiveness of Anti-Bribery Training

To say anti-bribery training is important is one huge understatement. It continues to be one of the key elements in any effective or any best practices compliance program. The US Sentencing Guidelines contains clear language:...more

Want to Keep the DOJ Away? Get Clear Anti-Corruption Policies and Good, Interactive Employee Compliance Training

Two of the key components of any best practices compliance regime under any anti-bribery and anti-corruption program are policies and training. Policies tie together a company, its business environment, the risks it faces and...more

UK SFO Drops High-Profile Corruption Case

The trial of Victor Dahdaleh in London has collapsed due to the absence of key prosecution witnesses. The UK’s Serious Fraud Office (SFO) recently dropped its case against Victor Dahdaleh, the British-Canadian...more

New Anti-Corruption Law to Take Effect in Brazil

With the continued ongoing work to exploit the discoveries in the Lula (Tupi) field and the recently announced 2013 subsalt strike in the Campos and Santos basins off Brazil's southern coast, oil and gas exploration and...more

China Issues New Regulations Prohibiting Commercial Bribery in the Health Care Industry

In late December, China’s National Health and Family Planning Commission ("NHFPC"), the successor organization to the Ministry of Health, issued two sets of anti-corruption regulations for the health care industry: the 2013...more

Inspector Lestrade – Does Leadership Matter?

Continuing our Sherlock Holmes homage, today we draw inspiration from the character of Inspector Lestrade as the theme of this blog post. I thought about Inspector Lestrade when I read some of the comments of UBS Chief...more

Getting Your Company Ready For M&A Compliance Due Diligence

Who was the absolute worst general during the Civil War? While there are many worthy candidates for this dubious honor, on the Southern side my vote goes to General John Bell Hood. ...more

Law Firms Forecast Strong FCPA Enforcement in 2014

Three law firms — Gibson, Dunn & Crutcher, Hughes Hubbard & Reed and Shearman & Sterling — recently issued reports in which they anticipated vigorous enforcement of the Foreign Corrupt Practices Act (FCPA) higher criminal...more

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

UK Government Steps Up Antibribery Enforcement

Recent actions by the Serious Fraud Office and Financial Conduct Authority indicate an increased focus on addressing allegations of bribery and corruption. It is clear that, in the wake of the Bribery Act 2010, the UK...more

Walk a Straight Line — Even if All Roads Are Crooked

The person who said "When in Rome, do as the Romans do" did not have to contend with the U.S. Foreign Corrupt Practices Act (FCPA). Although bribery is an integral part of daily life in many countries and can seem a...more

2014 Trends: #2 Navigating the Myriad Anti-Corruption and Bribery Laws

Earlier last week we began discussing the top ten trends in ethics and compliance we identified for 2014. Third party risk as the ethics and compliance “Achilles heel” dominated the conversation in our first trend. In this...more

We Mean What We Say – FCPA Enforcement Begins The Year With A Bang

Gone are the days when everyone wondered whether FCPA enforcement was slowing down. The Justice Department and the SEC have answered that question with a resounding statement – “We are here to stay.”...more

The World in US Courts: Decisions Discussed in This Issue: Fall 2013

Orrick is pleased to announce the third issue of The World in US Courts: Orrick’s Quarterly Review of Decisions Applying US Law To Global Business and Cross-Border Activities. This issue discusses 33 new decisions that...more

Brazilian Anti-Corruption Law: 7 Implications and Challenges for Companies Doing Business in Brazil

Brazil’s impending enforcement of its new global anti-corruption law underscores the importance of internal anti-corruption compliance programs. Brazil’s landmark anti-corruption statute will take effect 29 January...more

The FCPA Person Of The Year – The Prosecutor

To continue a “tradition” on Corruption Crime and Compliance, I like to end the year with recognition of the “person of the year,” referring to the institution which has had the most impact in the enforcement and compliance...more

FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions [Video]

In this episode, I review the corporate FCPA enforcement actions of 2013. ...more

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