Anti-Corruption

News & Analysis as of

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

Designing Cost Effective Risk Assessment Programs May 21, 2014 [Video]

The foundation of every anti-corruption ethics and compliance program is a risk assessment. It is important to design and implement a process to conduct an initial risk assessment, to update the risk assessment, and to ensure...more

Code of Conduct, Compliance Policies and Procedures-Part IV

This is the fourth and final installment of my series on the the importance of a Code of Conduct and anti-corruption compliance policies and procedures in your compliance program and how you should go about drafting or...more

Third-Party Due Diligence Checklist

A critical component to any anti-corruption program is third party due diligence. Our Third-Party Due Diligence Checklist, part of The Network's Third-Party Risk Solution, provides a template for gathering critical...more

Code of Conduct, Compliance Policies and Procedures-Part III

Today, I continue with Part III of my four-part series on the best practices surrounding your Code of Conduct and anti-corruption policies and procedures. In this post, I take a look at drafting policies and procedures. I...more

Code of Conduct, Compliance Policies and Procedures-Part I

For the remainder of this week, I will have a four-part episode on your Code of Conduct and anti-corruption compliance policies and procedures. In today’s post I will review the underlying legal and statutory basis for the...more

FCPA Compliance and Ethics Report-Episode 77World Cup Report-Part VII, with Mike Brown [Video]

In this episode of the FCPA Compliance and Ethics Report, Mike Brown and I conclude our World Cup Report series. We continue our look at some of the compliance and ethics lessons from the recently concluded World Cup. ...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

Shelter from the Coming Storm: Anti-Corruption Compliance in European Public Procurement

A red sky at morning is the traditional harbinger of ill weather. From our vantage point in Brussels, we’ve scanned the horizon for signs of the future of anti-bribery enforcement activity in Europe. We’ve identified four...more

Monitoring and Auditing Your Anti Corruption Compliance Program  [Video]

Companies have designed and implemented anti-corruption compliance programs. An important element of an effective compliance program is monitoring and auditing the program to identify issues for improvement. Working in...more

The Network News

Fraud Index Released-Startling Findings - A survey of more than 1,400 organizations worldwide revealed startling 4th quarter results on fraud trends for 2013. The Fraud Reporting Percentage (FRP), which measures fraud...more

Survey: Anti-Corruption Laws Have Major Impact on Corporate Compliance Policies

With over $1.5 billion in fines assessed by the U.S. Securities and Exchange Commission for violations of the Foreign Corrupt Practices Act (FCPA) since 2010, corruption concerns are playing a larger role in corporate...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

GSK Faces a Bad Day at Black Rock

One of my favorite movies is Bad Day at Black Rock. It is one of the few movies to combine elements of film noir into something approaching a traditional Western. It also attacks directly the prejudice and hate against...more

Anti-Corruption Digest

Anti-Corruption Digest is an update distributed on a monthly basis by Dorsey & Whitney providing a summary of the latest developments in anti-corruption enforcement activity around the world. In This Issue: -...more

Case Bulletin: R v Karigar, 2014 ONSC 3093

For the first time in Canada, an individual has been sentenced to jail time for bribing a foreign public official. The three-year penitentiary sentence was handed down by the Ontario Court of Justice under the Corruption of...more

First Jail Sentence Under Canada’s Corruption of Foreign Public Officials Act Sends Strong Message to Business Community

Ed. Note-recently it was announced that Canada had made its first Canadian anti-corruption law, the Corruptions of Public Officials Act. I ask John Boscariol, a partner at McCarthy Tétrault LLP if he could explain the...more

Will TRACE Certify the World?

Aaron Hernandez, former of New England Patriots tight end, was indicted for murder this week, allegedly killing a man for spilling his drink at a bar. But fatal disputes originating in taverns are not anything new as on this...more

Canada Continues Strong Enforcement of Anti-Corruption Laws with First Individual Conviction

Canada's first conviction of an individual under the Corruption of Foreign Public Officials Act (CFPOA) is expected to set a precedent for future corruption cases as regulators continue their crackdown on global corruption....more

Court Issues Rare Guidance on When State-Owned Enterprises Are “Instrumentalities” of Foreign Governments

In United States v. Esquenazi, No. 11-15331 (11th Cir. May 16, 2014) the United States Court of Appeals for the Eleventh Circuit recently set forth a test for evaluating when the executives and employees of a company owned or...more

Eleventh Circuit Adopts Broad Definition of Government "Instrumentality" in Recent FCPA Case - Ruling Underscores the Need to...

The Foreign Corrupt Practices Act (FCPA) makes it unlawful for a person or company to provide money or anything of value to any foreign official in order to obtain or retain business or to acquire an improper business...more

Eleventh Circuit Defines “Instrumentalities” of Foreign Government for the Purposes of the Foreign Corrupt Practices Act

In general, the Foreign Corrupt Practices Act (“FCPA”) prohibits the payment of money or anything of value to a foreign official in order to influence any act or decision of the foreign official in his or her official...more

Court of Appeals Hands Down Landmark FCPA Ruling Defining the Term “Instrumentality”

Federal appellate court decisions interpreting the Foreign Corrupt Practices Act (FCPA) are rare. Very rare. Indeed, in the statute’s 36-year history there have been barely more than a handful of appellate court decisions...more

11th Circuit First To Define “Instrumentality” Under FCPA

On May 16, the U.S. Court of Appeals for the Eleventh Circuit became the first circuit court to define “instrumentality” under the FCPA. U.S. v. Esquenazi, No. 11-15331 (11th Cir. May 16, 2014)....more

Esquenazi Opinion Extends Reach of FCPA, Adopting Broad Definition of “Instrumentality of a Foreign Government”

On May 16, 2014, the U.S. Court of Appeals for the Eleventh Circuit issued a highly anticipated decision construing the scope of the term “instrumentality” under the Foreign Corrupt Practices Act (“FCPA”). See U.S. v....more

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