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Top Ten International Anti-Corruption Developments for November 2014

For busy in-house counsel and compliance professionals, we have tried to summarize the most important international anti-corruption developments in the past month with links to primary resources. November was definitely a...more

FCPA Compliance and Ethics Report-Episode 110-interview with Jonathan Armstrong [Video]

In this episode I visit with Jonathan Armstrong a partner in Cordery in London. He visits with me about his new firm, the equity investment of Lexis/Nexis in his firm and some of the trends he sees in cross-border...more

Sharing the Spotlight: M&A Due Diligence

Everyone likes to talk about the importance of due diligence. A whole new due diligence industry has grown, starting with initial anti-money laundering requirements and stretching into corruption and sanctions issues....more

8 Tips for Verifying the Effectiveness of Corporate Anti-Corruption Programs

In the past 20 years, considerable progress has been made in developing corporate anti-corruption programs, as companies recognize the damaging effects of bribery and corruption on business, reputations and the global...more

Top 10 tips for countering small bribes

The issue of so-called facilitation payments and other small bribes is a thorn in the side of many international businesses. Not only is it difficult to do business in many parts of the world without making such payments, but...more

Bad News Barnes and China’s Overseas Efforts to Fight Corruption

I thought about Bad News Barnes whilst reading some recent Financial Times (FT) articles about China’s fight against corruption. They were “China takes its anti-corruption battle to foreign shores” and “China bribe cases pose...more

Where the Action Is: The SCCE Annual Meeting

If anyone wants proof that the compliance profession is on the rise, if anyone still doubts that the young professional of compliance is rapidly growing, all you have to do is attend an annual meeting of the Society of...more

Internal Controls for Third Party Representatives in a FCPA Compliance Program

This week, I am continuing my podcast series, on the FCPA Compliance and Ethics Report, on internal controls in best practices anti-corruption compliance program, under the Foreign Corrupt Practices (FCPA), UK Bribery Act or...more

The Human Factor: Joint Venture Partner Compliance (Part III of III)

It is time for another in my series of profound grasps of the obvious – compliance comes down to people. A company violates its code or the law because of human actions or inaction....more

Review: The Foreign Corrupt Practices Act in a New Era

Broadly speaking, the Foreign Corrupt Practices Act prohibits offering or paying anything of value to a foreign official to obtain or retain business. Recent years have seen a boom in FCPA compliance efforts and enforcement...more

Inside and Out: Anti-Corruption Compliance for Joint Ventures (Part II of III)

A joint venture can create layers and layers of risk for compliance officers. It is always good to start from the inside and work your way out. If your joint venture partner is a state-owned enterprise, or even more...more

Management of Corruption Risks – Business Lessons from GSK

The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have made it abundantly clear over the past several years that companies should assess their risk and then manage their own risks....more

The 10 Essential Steps to Implement an Effective Anti-Corruption Compliance Program [Video]

The Department of Justice's and the SEC's FCPA Guidance issued last November, 2012, outlined the hallmarks of an "effective" anti-corruption compliance program. In the FCPA Guidance, the Justice Department and the SEC...more

Creative Contracting to Reduce Third-Party Risks (Part III of IV)

Most lawyers are not creative people. After all, there is a reason they went into the law. Lawyers who deal with anti-corruption risks and third parties need to expand their horizons and consider using creative solutions to...more

Integrating and Training Your Agents and Distributors (Part II of IV)

The Department of Justice and the SEC know they can push companies to expand and improve their anti-corruption compliance programs. They are well aware that the requirements set forth in their settlement documents, as well as...more

Building An Effective Anti Corruption Compliance Program [Video]

Companies are devoting more time and attention to building a robust anti-corruption compliance program. As they do so, it is important to design the right structure for the compliance program -- from the Corporate Board, to...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

How to Monitor, Audit and Improve 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

The Whole World Is Watching Mexico In the Fight Against Corruption

I have written about business solutions to legal problems, such as the FCPA, in the energy industry here in Houston. Noted compliance practitioner Scott Killingsworth made similar observations on compliance covenants in...more

Bribery, Twice Removed

Charles Duross is the head of Morrison & Foerster’s Global Anti-Corruption Practice. He is the former head of the Department of Justice’s Foreign Corrupt Practices Act unit, where he took a leading role in developing and...more

Fine Tuning Your Anti Corruption Compliance Program [Video]

In this era of aggressive FCPA enforcement, companies are adopting anti-corruption compliance programs. The Department of Justice and the SEC have warned companies against adopting "paper compliance programs" without...more

Building an Anti Corruption Compliance Program Practical Steps 2 18 14, 9 02 AM [Video]

Companies face many risks in the anti-corruption enforcement arena. With the growing globalization of anti-corruption enforcement, companies are responding quickly by enhancing their anti-corruption compliance...more

Five Most Common Weaknesses in Anti-Corruption Compliance Programs

In this Internet-age of ADHD and simplistic thinking, I thought I would contribute this week by putting together some lists of common themes in the ethics and compliance world. Unfortunately, we are all addicted to quick...more

Continuous Improvement Of Your Compliance Program, Part II

Anti-corruption, anti-bribery, anti-money laundering (AML) programs policies and procedures and even export control systems are seemingly in a constant state of evolution. Many companies are struggling with the challenge of...more

Managing Your Anti Corruption Policies and Procedures  [Video]

In response to the aggressive enforcement environment, companies have adopted robust anti-corruption policies and procedures. As always, the effectiveness of a company's policies depends on implementation, management and...more

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