The FCPA Compliance and Ethics Report-Episode 66, Visit with Virna De Palma from TRACE
FCPA Compliance and Ethics Report-Episode 38-Using a utility industry compliance program as a guide to anti-corruption compliance
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
Fine Tuning Your Anti Corruption Compliance Program
FCPA Compliance and Ethics Report-Episode 23 with Jay Rosen on the Importance of Translations in Your Compliance Program
Corporate Criminal Liability – Interview with Bridget Rohde, Member, Mintz Levin
FCPA Compliance and Ethics Report-Episode 15-GSK in China: a Game Changer in Compliance
In this episode I visit with Virna De Palma,Senior Director, Global Strategy & Communications at TRACE International, Inc.. She talks about some of the services which TRACE offers and details a new and exciting scholarship...more
The Financial Conduct Authority (FCA) has fined Besso Limited, an independent management owned general insurance broker in the Lloyd’s Broking group, £315,000 for a failure to take reasonable care to establish and maintain...more
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
Two of the key components of any best practices compliance regime under any anti-bribery and anti-corruption program are policies and training. Policies tie together a company, its business environment, the risks it faces and...more
The trial of Victor Dahdaleh in London has collapsed due to the absence of key prosecution witnesses.
The UK’s Serious Fraud Office (SFO) recently dropped its case against Victor Dahdaleh, the British-Canadian...more
With the continued ongoing work to exploit the discoveries in the Lula (Tupi) field and the recently announced 2013 subsalt strike in the Campos and Santos basins off Brazil's southern coast, oil and gas exploration and...more
In late December, China’s National Health and Family Planning Commission ("NHFPC"), the successor organization to the Ministry of Health, issued two sets of anti-corruption regulations for the health care industry: the 2013...more
Continuing our Sherlock Holmes homage, today we draw inspiration from the character of Inspector Lestrade as the theme of this blog post.
I thought about Inspector Lestrade when I read some of the comments of UBS Chief...more
Who was the absolute worst general during the Civil War? While there are many worthy candidates for this dubious honor, on the Southern side my vote goes to General John Bell Hood. ...more
Three law firms — Gibson, Dunn & Crutcher, Hughes Hubbard & Reed and Shearman & Sterling — recently issued reports in which they anticipated vigorous enforcement of the Foreign Corrupt Practices Act (FCPA) higher criminal...more
Following a relatively flat enforcement landscape and some bumps in the 2013 prosecutorial road, the Department of Justice (‘‘DOJ’’) and the Securities and Exchange Commission (‘‘SEC’’) appear poised to spring back into...more
Recent actions by the Serious Fraud Office and Financial Conduct Authority indicate an increased focus on addressing allegations of bribery and corruption.
It is clear that, in the wake of the Bribery Act 2010, the UK...more
The person who said "When in Rome, do as the Romans do" did not have to contend with the U.S. Foreign Corrupt Practices Act (FCPA). Although bribery is an integral part of daily life in many countries and can seem a...more
Earlier last week we began discussing the top ten trends in ethics and compliance we identified for 2014. Third party risk as the ethics and compliance “Achilles heel” dominated the conversation in our first trend. In this...more
Gone are the days when everyone wondered whether FCPA enforcement was slowing down. The Justice Department and the SEC have answered that question with a resounding statement – “We are here to stay.”...more
Orrick is pleased to announce the third issue of The World in US Courts: Orrick’s Quarterly Review of Decisions Applying US Law To Global Business and Cross-Border Activities.
This issue discusses 33 new decisions that...more
Brazil’s impending enforcement of its new global anti-corruption law underscores the importance of internal anti-corruption compliance programs.
Brazil’s landmark anti-corruption statute will take effect 29 January...more
To continue a “tradition” on Corruption Crime and Compliance, I like to end the year with recognition of the “person of the year,” referring to the institution which has had the most impact in the enforcement and compliance...more
In this episode, I review the corporate FCPA enforcement actions of 2013. ...more
This episode 30 is Part 2 of my interview with the FCPA Professor. ...more
Last week Weatherford International Limited (Weatherford) concluded one of the longest running open Foreign Corrupt Practices Act (FCPA) investigations when it agreed to the eighth largest FCPA fine of all-time and one of its...more
On August 1, 2013, in response to the Organization for Economic Co-operation and Development’s ("OECD") requirement that Brazil comply with the Convention on Combating Bribery of Foreign Public Officials in International...more
Do the intentions behind enforcement of domestic or international anti-corruption laws matter? Or is ‘the law the law’ and it really does not matter what a government’s motives are in enforcing laws that it has on the books....more
The Financial Conduct Authority has now completed its thematic review of Anti-Money Laundering and Anti-Bribery and Corruption Systems and Controls: Asset Management and Platform Firms (TR13/9). The review of 22 wealth and...more
Companies operating internationally often engage numerous – sometimes even thousands – of third parties around the world to help facilitate their business. Alongside the growth of such relationships, the risks posed by them...more
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