Anti-Corruption Audits

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Great Structures Week V – The Tacoma Narrow Bridge Failure and Preventing Failure in Your Compliance Program

I conclude my Great Structures Week with a focus on structural engineering failures: suspension bridges and the challenges of wind in their construction and maintenance. I am drawing these posts from The Great Courses...more

Pink Flamingos and the Compliance Audit

The creator of one of the most ubiquitous symbols of mid-century Americana died earlier this week. Don Featherstone, the creator of the pink plastic lawn flamingo, the ultimate symbol of American lawn kitsch, has died. He was...more

Implementing an Effective Third Party “Audit” Program

We all have our favorite episodes and scenes from the Seinfeld series. As we grow older, we like to reference them more and more – maybe because it reminds us of your “youth” (looking back, my 30s were certainly younger than...more

Anti-Corruption Compliance Program Audits [Video]

Companies are devoting more resources to monitoring their compliance and ethics programs. Whether the audit is conducted at corporate headquarters or in the field, there are important issues which should be examined during...more

Is Anti-Corruption a Business or Legal Issue?

On June 5, 2014, Philippe Montigny, President of Ethic Intelligence (www.ethic-intelligence.com) asks exactly that question in an editorial. My own perspective of compliance remains much along the lines of those such as Mr....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

Governance & Securities Law Focus: Europe Edition, April 2014

In this issue: - EU Developments - German Developments - UK Developments - Us Developments - Excerpt from EU Developments - European Commission Proposes to Introduce Shareholder "Say...more

Life Cycle Management Of Third Parties – Step 5 – Management Of The Relationship

Today ends my review of what I believe to be the five steps in the management of a third party under an anti-bribery regime such as the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act. On Monday, I reviewed Step 1 –...more

Will Independent Directors Be on the Hook for Failure of Internal Controls in FCPA Cases?

The Foreign Corrupt Practices Act ("FCPA" or "the Act") prohibits bribery of foreign public officials in order to obtain or retain business. In addition to its anti-bribery provisions, the FCPA contains accounting provisions...more

Broker-Dealers: Pay Attention To Government Audits And Examinations

The story of “The Boy Who Cried Wolf” applies with full force to the securities industry and the FCPA. ...more

Anti-Corruption High-Risk Audits

The Justice Department and the SEC should be credited with promoting new compliance strategies and best practices. Whatever you may think about the DOJ/SEC FCPA enforcement program, they have pushed businesses to enhance...more

The Cutting Edge Of Anti-Corruption Compliance: Proactive Audits

The FCPA world is fast-becoming the leader in new compliance strategies. The Justice Department and the SEC have embraced the requirement for conducting “proactive audits.”...more

The Lilly FCPA Enforcement Action (Part III) Lessons Learned from Russia

This Part III is the final installment of my review of the Eli Lilly and Company (Lilly) FCPA enforcement action brought by the Securities and Exchange Commission (SEC). In this Part III, I will review the FCPA issues that...more

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