News & Analysis as of

Don’t Lose a No-Hitter – Use of Questionnaire and Compliance Terms and Conditions

Before Jim Crane came along to purchase the Houston Astros and provide us all with some of the best lessons learned for the compliance practitioner, they had a long and storied history, even if part of that history included...more

Cooperation, Leniency, Internal Investigations, Self-Incrimination, Privilege and All That Jazz

I recently attended a Fraud Conference in Miami where I heard a French lawyer insisting that since he was a defence advocate, his job was to defend his clients against fraud allegations, not to prosecute them. Instead of...more

A Secret UK Government Consultation–Is the Bribery Act About to Be Watered Down?

Through a Freedom of Information Act request, anti-corruption campaigners Corruption Watch obtained and released details of what they dubbed a “widespread, secret and one-sided consultation” by the Department of Business,...more

The Attacks in Paris and AML Compliance

The attacks in Paris and subsequent events have horrified any right-minded person. The slaughter of innocent civilians sickened the world and the outpouring of support for the city of Paris; the country of France and the...more

Best Practices for Anti-Corruption Training

For any company today, large or small, having a comprehensive anti-corruption compliance program in place is essential. To be effective, however, companies must clearly communicate and engage with employees and third parties,...more

Myths and Masks of Legislative Policy for Whistleblower Protection

Today’s guest post is by Wendy Addison, Founder and Owner of SpeakOut SpeakUp Ltd. What has become clear is that no matter which country you reside in, which industry you work in, whether you are male or female, ...more

Verifying Anti-Corruption Programs – Insights from TI-USA

Has your company implemented a program to prevent, deter and detect corruption? If so, have you verified it to ensure it is effective and appropriate for the level of risk faced by your company? Verification of...more

Top Ten International Anti-Corruption Developments for October 2015

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 in the past month with links to primary...more

Clean Hands, Smart Deals: A primer on complying with foreign anti-bribery laws

With the approaching financial year-end and the consequences of external audits, along with the new and increased risk of individual liability executives face in light of the recent Department of Justice “Yates Memorandum”,...more

Interview with Jonathan Marks

Ed. Note-I continue my series of blog posts on thought leaders in the compliance space today with an interview of Jonathan Marks, a Managing Director at Navigant. - Where did you grow up? I was born in New York...more

Assistant Attorney General Caldwell Provides Guidance on Corporate Compliance Programs

In her year and a half as Assistant Attorney General in charge of the Criminal Division, Leslie R. Caldwell has repeatedly emphasized the importance of a company having a compliance program fine-tuned to its specific risks to...more

DOJ Sharpens Focus on Corporate Compliance in Deciding Whether to Prosecute Companies

One of the factors that the U.S. Department of Justice (DOJ) considers in deciding whether to bring charges against a corporation is the existence and effectiveness of the corporation’s pre-existing compliance program. On...more

Common FCPA Issues

As our previous posts illustrate, violations of the Foreign Corrupt Practices Act (“FCPA”) can carry a hefty cost. Two issues are commonly the impetus for FCPA violations and, practically speaking, pose significant FCPA...more

DOJ Fraud Section Retains Hui Chen as Compliance Counsel Expert

Chen brings important industry experience to the role. The Department of Justice (DOJ) Fraud Section has retained Hui Chen as a “full-time compliance expert.” Ms. Chen comes to the position with compliance counseling...more

Cross-Border Investigations Update - November 2015

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases and enforcement trends, including developments in U.S. Foreign Corrupt Practices Act enforcement; the introduction of...more

Australian Anti-Bribery & Compliance Trends

Today we welcome Ted Williams, Partner, Piper Alderman. Ted, can you share some of your background and experience? TW: Thank you, Richard, for the opportunity to engage with your community, and it was a pleasure to...more

Tackling Corruption – Now A Truly Global Initiative?

There continues to be a global drive towards greater transparency and accountability in business. There are a number of factors at play here. ...more

Homeland, Brazilian Clean Companies Act Guidance and the Need for Accurate Translations in FCPA Compliance

He used to work in the movie business so you might think the production crew of the Showtime series Homeland would just give him a call. After all he is fast becoming known as ‘the translations guy’ in the Foreign Corrupt...more

[Webinar] Transparency International - USA - CREATe Webinar: From Policies to Practices: Embedding and Verifying Your...

How effective is your anti-corruption program? Companies of every size are vulnerable to legal, reputational and other risks due to corrupt activities among employees and third parties. Gain insights into leading practices...more

Anti-Corruption: Why Programs Fail

Today, companies around the world face daily challenges associated with corruption. This risk coupled with new laws and heightened enforcement are just a few of the factors driving companies to implement and improve...more

Layla and Other Love Songs and Risk Assessments

On this date in October 1971, Duane Allman died. He was the co-founder, along with his brother Greg, of the Allman Brothers Band. For my money he was one of the greatest guitarists of all time. At the time of his death, the...more

Focus on China - October 2015

Welcome to the third issue of Focus on China Compliance for 2015. According to the FCPA Blog’s October 2015 Corporate Investigations List, China leads the countries reported to be involved in FCPA investigations with 29...more

The Boss, the Hostess & the Invoice: A Compliance Dilemma

Today’s guest post is from Anthony Smith-Meyer, Editor-in-Chief, Business Compliance. Yesterday I was discussing motivation with my undergraduate class students. When you stop to consider this subject, you realise how...more

Building a Due Diligence Infrastructure (Part IV of IV)

A due diligence infrastructure is designed to demonstrate a company’s good faith commitment to compliance with anti-corruption laws by: identifying corruption risks; and mitigating such risks to ensure that the company does...more

New Whitepaper: Why Anti-Corruption Programs Fail: Turning Policies into Practices Launches Whitepaper Outlining Top Ten Ways Anti-Corruption Programs Fail and Insight into How to Embed Compliance across an Organization - Guidance for companies seeking to mitigate anti-corruption risks...more

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