News & Analysis as of

5 Takeaways From Former SAP Exec's FCPA Case

On Aug. 12, 2015, Vincente Garcia (former head of Latin American sales for SAP International Inc.) pled guilty in federal court in San Francisco to violations of the Foreign Corrupt Practices Act. In addition to pleading...more

[Event] Why Anti-Bribery Programs Fail and How Compliance Must Evolve - Sept. 17th, Boston, MA

In a “Catch Me If You Can” like panel, a former US and UN prosecutor and former FCPA violator/ turned cooperator discuss the realities of corporate anti-bribery compliance. It’s not often that compliance officers are...more

Give & Take: The Case for a Better G&E Compliance Program

Part One: Setting The Foundation - Why Does G&E Matter? Tony Robbins once said, “Every problem is a gift—without problems we would not grow.” In the compliance arena, the reverse also applies, as many gifts can...more

The BHP Case and Enforcement of The FCPA’s Internal Controls Provision

Ed. Note-today we have a guest post from Jean-Michel Ferat ,CPA, CFF is a Managing Director in the Washington D.C office of the Claro Group around his views on the BHP Billiton enforcement action. Much has been made in...more

A Summer of Compliance

When I was working in the field of international sales, August was typically a month of ‘down time’ as a combination of end user, third party and corporate holidays marked a lull in summer sales activity. Well, I have not...more

One Anti-Corruption Compliance Panel: Multiple Perspectives

On July 23rd, 2015 at the Hotel Kitano in New York City, The Network (www.tnwinc.com) hosted an Anti-Corruption Compliance Panel discussion titled “Why Anti-Bribery Programs Fail and How Compliance Must Evolve.” Cindy Curtin...more

Farewell to Moe Green and the Promise to Pay a Bribe Under the FCPA

Moe Green died again yesterday but this time he was not shot through the glasses, it was from cancer and the fictional Las Vegas mobster lived to the ripe old age of 79. Of course I am referring to “Alex Rocco, the veteran...more

How Companies Could Avoid “Paper” Compliance in New Ukraine? Try Acting Rather Than Talking

Ed. Note-today we have a guest post from two noted compliance practitioners from Ukraine, Timur Khasanov-Batirov and Andriy Selepey who discuss the dangers of a paper compliance program. Corruption is the main problem...more

[Event] Why Anti-Bribery Programs Fail and How Compliance Must Evolve - July 23, New York, NY

In a “Catch Me If You Can” like panel, a former US and UN prosecutor and former FCPA violator/ turned cooperator discuss the realities of corporate anti-bribery compliance. It’s not often that compliance officers are...more

[Webinar] How EU Companies Can Implement & Demonstrate Effective Anti Bribery Compliance in Emerging Markets - July 9, 9:00 am EST

European companies subject to FCPA jurisdiction or comparable European jurisdictions, and doing business in emerging markets such as the BRIC nations, face a rigorous compliance standard. Firms must have compliance processes...more

Foreign Corrupt Practice Act Update

Recent criminal indictments of FIFA officials should remind businesses to review their obligations under the Foreign Corrupt Practices Act (FCPA). Those who violate the FCPA can face civil and criminal penalties, including...more

The Foreign Corrupt Practices Act: At a Glance

In this issue: - FCPA AT A GLANCE - THE ANTI-BRIBERY PROVISIONS OF THE FCPA - TO WHOM THE ANTI-BRIBERY PROVISIONS APPLY - THE PAYMENT ELEMENT - THE CORRUPT INTENT ELEMENT - WHO IS A...more

FCPA: Anti-Bribery Provisions

The Foreign Corrupt Practices Act (FCPA) addresses the problem of international corruption in two ways: (1) the anti-bribery provisions prohibit individuals and businesses from bribing foreign government officials in order to...more

[Webinar] Mid-Sized Companies and Anti-Corruption: How to manage corruption risks with limited resources - May 28, 11:00 am EST

Instances of corruption can have a significant impact on a company’s finances and reputation. With international anti-bribery enforcement actions on the rise, it is essential for companies to implement an anti-corruption risk...more

FCPA Compliance and Ethics Report-Episode 149-Patrick Taylor of Oversight Systems on developments in transaction monitoring [Video]

In this episode I visit with Patrick Taylor, CEO of Oversight Systems on some of the newest developments in tools to facilitate transaction monitoring. ...more

December FCPA Enforcement Digest – Let’s Celebrate the New Year with Anti-Bribery Training!

Happy New Year! I hope everyone had a wonderful holiday and a great start to the New Year. With that said, I hope you’re not suffering from the holiday hangover (and I don’t mean the alcohol-induced kind.) After taking...more

The Origins of the FCPA - Lessons for Effective Compliance and Enforcement - Conclusion

This is the final part of an occasional series. The entire paper will be published by Securities Regulation Law Journal early next year. Conclusion: The FCPA Today - The FCPA was unique in the world at passage....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

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

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

Tribute to Stan The Man and 11 Rules for Compliance Success

Today we honor Stan ‘The Man’ Musial who played 22 seasons for the St. Louis Cardinals (1941–1963) who passed away on Saturday. Musial was a record 24-time All-Star selection and is widely considered to be one of the greatest...more

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