Anti-Corruption

News & Analysis as of

France Considers New Anti-Corruption Authority

France has introduced a draft bill which proposes to establish a new anti-corruption authority, which will have the power to impose administrative sanctions and conduct US-style monitoring of companies’ anti-bribery...more

Dubai introduces new economic security centre regulator

In an effort to maintain Dubai's status as a global financial and economic hub, a new economic security regulator, the Dubai Economic Security Centre (DESC) has recently been established in the Emirate....more

The Evolution of Compliance: Structural Changes Which Led to Compliance 2.0

If there was one theme from Compliance Week 2016 it was the continued evolution of the Chief Compliance Officer (CCO) role and the compliance profession. Long gone are the days when someone is sent over from a legal...more

UK Financial Regulatory Developments - May 2016 #13

Pensions guidance rules come into force - The second commencement order under the Bank of England and Financial Services Act 2016 brings into force from 13 May the provisions on pensions guidance, which extend the...more

ISO 37001: A New Measuring Stick for Corporate Compliance Programs

The International Organization for Standardization is developing a certifiable international standard for “anti-bribery management systems” that could influence how the US Department of Justice, US Securities and Exchange...more

Citadel, a $24-Billion Hedge Fund, Seeks Whistleblower Status

Just a few months after announcing the first-ever award to an outside whistleblower, federal authorities may be on the verge of expanding the reach of whistleblower incentives even further. Last week, Citadel, the...more

Corruption Risks and Corporate Social Responsibility Spending

Global companies have been embracing socially responsible spending projects to build stronger relationships with local communities. The idea makes a lot of sense and real projects can result in real benefits....more

Up Close and Personal: Individual CCO Liability – Part I

A horse is a horse, of course, of course, and no one can talk to a horse, of course. That is, of course, unless the horse is the famous Mister Ed. Those lines were the opening verse to the theme song of the TV...more

The Evolving Due Diligence Standards and Beneficial Ownership

In case you are not following all the latest scandals – Unaoil and the Panama Papers being two significant ones – we are seeing an evolution and possibly a revolution in due diligence expectations....more

Information shared by World Bank Group with RCMP protected from disclosure

Corruption crosses borders and anti-corruption efforts require cooperation - On April 29, 2016, the Supreme Court of Canada released its much anticipated decision in World Bank Group v. Wallace. The decision highlights...more

Joe Howell on the PCAOB, Audits and Compliance – Part II

Today we have Part II of my exploration with Joe Howell about the PCAOB and how its work with public company auditors impacts anti-corruption compliance. I asked Howell about auditor rotation and what it means. Howell...more

Joe Howell on the PCAOB, Audits and Compliance – Part I

I recently had the chance to visit with Joe Howell, the Executive Vice President (EVP) of Workiva LLC. Howell has been the Chief Financial Officer (CFO) of a number of public companies, mostly in the technology space, and...more

Anti-Corruption Summit: Extending Corporate Liability for Economic Crimes?

In a keynote address at the London Anti-Corruption Summit, Prime Minister David Cameron raised the possibility of new U.K. legislation to make corporations liable for “failure to prevent” fraud or money-laundering offenses...more

DOJ Proposes Legislation Intended to Advance Anti-Corruption Efforts

On May 5, the DOJ announced that it plans to submit to Congress proposals for legislative amendments that would provide the DOJ with additional tools to advance anti-corruption work in the areas of pursuing illegal proceeds...more

The Pen is Mightier than the Compliance Sword

Nicole Rose brings a breath of fresh air to compliance. 6 years ago she swapped her legal practicing certificate for her pen and has been thriving ever since. She founded Create Training almost 3 years ago, and over this...more

The Anti-Corruption Summit – UK Plans For A New Corporate Money-Laundering Offence, And A Host Of Other Proposals

On May 12, 2016, the UK’s Prime Minster David Cameron hosted the “Anti-Corruption Summit”, a first of its kind, bringing together world leaders, business, and civil society with the goal of seeking to agree on a package of...more

Bribery and Corruption in International Arbitration

Corruption in international business is becoming endemic. Transparency International's latest Global Corruption Report highlights that nearly two in five business executives say they have been asked to pay a bribe when...more

Top Ten International Anti-Corruption Developments for April 2016

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 from the past month, with links to primary...more

FinCrimes Update - April 2016 Summary, Volume 4, Issue 4

AML/BSA & OFAC: FINCEN ANNOUNCES DEPARTURE OF DIRECTOR CALVERY - On April 26, FinCEN announced the departure of Director Calvery. Commenting on Calvery’s accomplishments during her tenure as Director, the agency...more

ANAC cambia rotta, il Codice dei Contratti Pubblici riguarderà solo bandi e avvisi pubblicati dopo il 20 aprile 2016

The ANAC has changed opinion: the new Code of Public Contracts will cover only notices published with effect from 20 April 2016. With a Press Release of 3 May 2016, the National Anti-Corruption Authority ( "ANAC")...more

FCPA (and my) Failure

I haven’t thought too much about failure lately, until I read Roy Snell’s piece, “We Are All Victims…Except Richard Bistrong.” Roy’s article took me by surprise, as his blog piece addresses a primary foundation of my work:...more

Are new Government AML/CTF proposals a step too far?

On 21 April 2016, the Government released its new Action Plan for anti-money laundering (AML) and counter-terrorist finance (CTF). The Action Plan contains a number of AML/CTF proposals on which the UK Government wishes to...more

What is a Compliance Evangelist?

What does it mean to be the Compliance Evangelist? A colleague put that question to me last week. This friend is a loyal and long time reader of my blog and listener of my podcast and I thought if it was not clear to her,...more

The World Bank Sanctions System & Anti-Corruption Efforts

In this Q&A, CREATe’s anti-corruption expert Leslie Benton talks with the World Bank’s Pascale Hélène Dubois about a topic that was covered in a webinar on April 22nd, entitled Hot Topics in Anti-Corruption Enforcement and...more

World Bank v. Wallace: SCC Endorses Importance of International Anti-Corruption Efforts

On April 29, 2016, the Supreme Court of Canada (SCC) upheld archival and personal immunities of an international organization (the World Bank Group) and its anti-corruption investigators. The SCC’s decision in World Bank...more

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