Anti-Corruption

News & Analysis as of

Five on Friday – Five Recent Developments that We’ve Been Watching Closely

It’s Friday and time for another overview of developments in the field of business and human rights that we’ve been monitoring. This week’s post includes: recent developments with regard to a major Alien Tort Statute...more

Red Notice Newsletter - January 2016

ANTICORRUPTION DEVELOPMENTS - Convicted Printing Company Ordered to Pay £2.2 Million - On January 8, 2016, the Serious Fraud Office (SFO) announced that Smith & Ouzman Ltd, a U.K. security printing company, was...more

Corruption and Foreign Government Institutions

The FCPA can create a very one-sided view of corruption. The bribe payer is punished and most times the recipient is not. The Justice Department has used creative approaches to ensnare recipients as in the Direct Partners...more

2015 Corruption Perceptions Index, a Vital Anti-Bribery Compliance Tool, Highlights Global Corruption Risks for Corporations

On January 27, 2016, Transparency International released its 2015 update to its annual “Corruption Perceptions Index” (“CPI”), a vital resource for corporate anti-corruption compliance efforts. The 2015 CPI rates 168...more

New anticorruption legislation: how to protect your business against possible risks?

"Having clear, understandable and effective corporate rules is the best protection against possible risks" Since its independence, Kazakhstan has made significant progress in combatting corruption and bribery. However,...more

Global Focus on Anti-Corruption Continues: Transparency International Releases Corruption Perceptions Index 2015

On January 27, 2016, Transparency International published its Corruption Perceptions Index (CPI) for 2015. The 2015 edition ranks 168 countries based on the perceived level of corruption in the country’s public sector....more

Practical aspects of anticorruption legislation in Kazakhstan

Having clear, understandable and effective corporate rules is the best protection against possible risks Since its independence, Kazakhstan has made significant progress in combatting corruption and bribery. However,...more

2016 Trends #5: The Wide World of Sports

If 2016 is anything like last year, we can count on the world of sports to provide a variety of fodder for ethics and compliance discussions. Sports scandals now rival political and business ethics scandals as the...more

The FCPA Risks of Teaming in the Defense Industry

As reported in the December 25, 2015 New York Times (NYT) article, “U.S. Foreign Arms Deals Increased Nearly $10 Billion in 2014,” “foreign arms sales by the United States jumped by almost $10 billion in 2014, about 35...more

Bribery Requires – Money

I have to confess – I love the show Shark Tank. Mr. Wonderful, Kevin O’Leary, is my favorite Shark. Mr. Wonderful often reminds the contestants and other Sharks that the central issue in considering business proposals is –...more

Anti-Corruption Compliance beyond Headquarters: Improving Practices in Subsidiaries and Regional Offices

Effective anti-corruption compliance programs are fundamental in today’s corporate environment. However, even the most comprehensive controls put in place by companies may face difficulties in execution. It is not uncommon,...more

U.S. and China Sign Financial Intelligence Cooperation Memorandum

The U.S. Financial Crimes Enforcement Network (FinCEN) and the China Anti-Money Laundering Monitoring and Analysis Center (CAMLMAC) recently signed a Memorandum of Understanding (MOU) to create a “framework to facilitate...more

Top Ten International Anti-Corruption Developments for December 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

Is Your Anti-Corruption Compliance Program “Operational”?

The Justice Department and the SEC are tired of investigating companies with “paper” compliance programs. It is easy to spot a “paper” compliance program – as the saying goes, you can smell it a mile away....more

Health Care Enforcement in 2016: A Look Back on 2015 and Forecasting the Year Ahead

2015 was a year of transition for the U.S. Department of Justice (“DOJ”), with the installation of a new Attorney General, Deputy Attorney General, and several other high-level officials. In January 2015, Andrew Weissmann...more

Trending in 2016: Six Anticorruption Developments to Watch

With huge international scandals, such as those involving FIFA and Petrobras, dominating media coverage, bribery and corruption issues remained at the forefront for many throughout 2015. But what will the next year hold? ...more

Legal Trends: Litigation & Dispute Resolution

In 2016, regulated persons in Canada are increasingly likely to find themselves facing prosecution before tribunals, rather than in courts, and facing significant exposure to monetary penalties in those...more

2016 Trends #2: Transitioning to a More Global Center of Gravity for Ethics and Compliance

Today, many ethics and compliance professionals, no matter where we’re located, find it to be important to keep up-to-date on the latest news from the European Union courts, the U.K.’s Serious Fraud Office and international...more

Predictions for Anti-Corruption Enforcement for 2016

In all honesty, if I were betting on my predictions, I would be broke. If I were setting the line on the Super Bowl, I am sure I would go bankrupt in paying off bets. With such confidence, you may want to just click to the...more

Hiring and Compliance: Evaluating Candidates and Setting Expectations

Today I want to talk about two different techniques that your HR function can use to help the compliance function by honoring two very different yet equally famous baseball players who died on Sunday. The first was Jim...more

Tribute to Bob Fox-The Fair Process Doctrine in Compliance

Today’s is a personal blog post. My father, Dr. Milden Jean Fox, Jr. “Bob” passed away last week. He was born in 1926 and was part of what we rightfully call the “Greatest Generation”. We call them this for a whole host of...more

Year-End Sales Targets and Anti-Corruption Compliance: A Potential Clash?

Even the most well-designed anti-corruption compliance programs often fail. Why? According to a new whitepaper from CREATe.org, top reasons include a failure to assess risks, lack of leadership, and insufficient human and...more

Top Ten International Anti-Corruption Developments for November 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

FinCrimes Update - November 2015 Summary, Volume 2, Issue 9

FINCEN DIRECTOR HIGHLIGHTS THE SIGNIFICANCE OF SAR FILINGS - On December 9, FinCEN Director Calvery highlighted at a joint FBIIC-FSSCC meeting the role of FinCEN in gathering and analyzing financial intelligence and the...more

Best Practices to Avoid Common FCPA Violations: Third-Parties

While the Foreign Corrupt Practices Act (“FCPA”) is an extremely complex act, there are two common FCPA violations of which automotive companies with international operations should be particularly sensitive. We recently...more

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