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Corruption, Risk and Business Strategy. Which one manages the others?

Since I stared writing about issues relating to compliance at the front line of international business, I have found myself looking more and more at the role of business strategy as a significant foundation of anti-bribery...more

5 CEO’s Who Should Be Forced To Retake Anti Bribery Training

5 CEO’s Who SIn my last blog I wrote about billionaire Bernie Ecclestone bribing his way out of a bribery sentence; I’m still shaking my head on that one. Sadly, he is not the only mega rich businessman behaving badly,...more

Did Bernie Ecclestone Skip Anti Bribery Training?

It astonishes me how many cases there are of wealthy individuals simply buying their way out of trouble. Let’s face it, in the world we live in today, money still talks, even in courts of law. Maybe this mentality was...more

A solid business strategy as the foundation of Anti-Bribery Compliance

Ethical Boardroom was kind enough to ask me to share my thoughts on what management techniques exist for promoting a cost effective FCPA or UK Anti-Bribery program across a global organisation. Clearly, there is no shortage...more

What happens when business strategy becomes a red-flag for bribery?

Richard Bistrong spent much of his career as an international sales executive. He was the Vice President of International Sales for a large, publicly traded manufacturer of police and military equipment, which included...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

FCPA Training: The Basics [Video]

This webinar provides a basic FCPA training program. A number of webinar attendees have requested that I conduct a basic FCPA webinar outlining how the FCPA statute applies to international business operations. The topics...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

Implementing Compliance Incentives In Your Company

Several readers have asked why I have not written anything about the Houston Astros this year. The answer is two-fold. The first is that I really do not care. However, the more I thought about it, the real reason is that they...more

North America Far Behind Europe in Fight against Global Corruption

North American companies lag behind the rest of the world when it comes to implementing anti-bribery training and policies, according to recent statistics from The Conference Board Inc.(TCB). ...more

Business Litigation Reporter - March 2014

In This Issue: Main Article: ..Russia’s Recently Enacted Anti-Bribery Laws Noted With Interest: ..Are Courtroom Technology Costs Reasonably Necessary To The Conduct Of Litigation In California...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

New Energy Opportunities in Mexico Raise FCPA, Anti-Bribery Risks

Sweeping reforms across Mexico’s oil, gas and electric markets promise more opportunities for the private sector and increased investment from international firms. However, U.S. companies looking to enter this market will...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

The Engineer’s Thumb And How To Bribe

We conclude our week of Sherlock Holmes inspired themes with one of the few cases in which Holmes fails to bring the criminals to justice, The Adventure of the Engineer’s Thumb. Once again using the Holmes tale as a...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

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