News & Analysis as of

Anti-Corruption Compliance

SCCE Compliance and Ethics Institute – Eugene Soltes and How Compliance Programs Works

by Thomas Fox on

The first full day of the SCCE 2017 Compliance and Ethics Institute (CEI) featured a talk by Eugene Soltes, an associate professor at Harvard Business School and author of “Why They Do It”. For this book Soltes spent over...more

A Closer Look at ISO 37001 – Something Old or Something New? (Part I of V)

by Michael Volkov on

The release of ISO 37001 has triggered an important discussion among legal and compliance professionals. In a five-part series, I plan to address the value of ISO 37001, provide a substantive analysis, and to evaluate the...more

What progress has been made by France as regards the fight against corruption?

by Bryan Cave on

The Group of States against Corruption of the Council of Europe (GRECO) released a report on 28 September 2017 of its assessment of the measures adopted by France to fight against corruption following the recommendations it...more

Anti-Corruption Update: A Global Perspective

by Bryan Cave on

Anticorruption conventions and legislation have global reach and introduce compliance demands on companies to prevent bribery. If your business operates on the global market, there is a risk that your employees or...more

Thaler Wins the Nobel Prize and Informs Compliance Programs

by Thomas Fox on

Richard H. Thaler won the Nobel Prize in Economics yesterday. Binyamin Appelbaum, reporting in a New York Times (NYT) a piece entitled, “Nobel in Economics Is Awarded to Richard Thaler”, wrote that “Thaler, whose work has...more

We Can Ignore This French Sapin II Law, Right?

by Bryan Cave on

Wrong. The law Sapin II (Law 2016-1691 of 27 December 2016) has been in force for several months, but the consultation draft of the guidelines is not expected to be issued by the Agence Française Anti-corruption (AFA) (French...more

China’s ‘One Belt, One Road’ Initiative Creates Opportunities and Regulatory Challenges

In a time of shifting opinions on the benefits of globalization, China’s “One Belt, One Road” initiative (OBOR) offers an unexpected bright spot for multinational companies able and willing to participate in this...more

Diwali: An Opportune Time for an Anti-Corruption Compliance Reminder

by Foley & Lardner LLP on

This year, India celebrates Diwali on October 19, 2017. “The Festival of Lights,” as Diwali (or Deepavli) is commonly called, is celebrated across India with great aplomb, joy and, of course, delicious sweets. Diwali...more

Anti-Corruption Risks and Drug and Device Companies

by Michael Volkov on

For years, the Justice Department and the Securities and Exchange Commission touted the FCPA “sweep” of the pharmaceutical and medical device industries. With good reason, DOJ and the SEC turned the drug and medical device...more

DOJ Announces Enhanced Enforcement of Healthcare FCPA Compliance

by Holland & Knight LLP on

The Department of Justice’s (DOJ) Criminal Fraud Section announced a new partnership between DOJ’s Healthcare Fraud Unit’s Corporate Strike Force and Foreign Corrupt Practices Act (FCPA) prosecutors. The partnership is meant...more

Using a Human Rights Lens to Strengthen Your Anti-Corruption Compliance Program

Companies are increasingly expected to manage the human rights impacts of their activities. This expectation is embedded in new legislative requirements, in the requirements of business partners and investors, and in the...more

FCPA Risks and Acquisition Integration Challenges

by Michael Volkov on

Chief compliance officers have devoted significant efforts to conducting pre-acquisition due diligence of a proposed target companies. I do not intend to diminish the importance of pre-acquisition due diligence, but I have...more

Anti-Corruption Compliance: The Need to Look Under the Cloak of Materiality

by Michael Volkov on

Sarbanes-Oxley revolutionized the auditing profession. Section 404 imposed stringent requirements for disclosure of the state of a company’s internal controls and financial reporting. The company’s independent auditor is...more

White Collar Watch (July 2017 • Vol 1, Issue 2)

by Blank Rome LLP on

Welcome to the summer edition of Blank Rome’s White Collar Watch. In a world that seems to bring new challenges daily—such as the global cybersecurity attacks that were launched in late June—this newsletter is designed to...more

FCPA under the New Administration

by Blank Rome LLP on

The single most frequently asked question by our international clients over the past several months is whether there will be changes in white collar prosecution priorities under the new administration, specifically with...more

Important Polling Results from BVD Webinar on Beneficial Ownership

by Michael Volkov on

On July 5, 2017, Bureau Van Dijk, a sponsor of my blog, conducted a webinar on the importance of beneficial ownership information to corporate compliance functions....more

Oh, Hadn’t You Heard? You’re Violating French Law Right Now! France Gets Serieuse about Anti-Corruption

Ok, ok, don’t panic. Maybe not all of the millions of dedicated readers of this blog are in violation. Nevertheless, as of June 1, if your company does business in France, it may be time to check your anticorruption...more

DOJ Releases Useful Corporate Compliance Resource

by Baker Donelson on

The Criminal Division’s Fraud Section of the Department of Justice (“DOJ”) published an “Evaluation of Corporate Compliance Programs” (the “Compliance Manual”) which offers guidance on the common questions contemplated by...more

Anti-Corruption Enforcement in Mexico: Your Integrity Policy Matters

by Bracewell LLP on

On July 19, 2017, Mexico’s General Law of Administrative Accountability will go into effect. It is the final part of a historic package of far-reaching anti-corruption laws, dubbed the National Anti-Corruption System, that...more

Red Notice Newsletter - June 2017

ANTICORRUPTION DEVELOPMENTS - Linde Group Receives DOJ Declination Pursuant to FCPA Pilot Program - On June 16, 2017, German based chemical and gas company Linde Group’s American affiliates, Linde North America Inc....more

What Happened in Oslo Shouldn’t Stay in Oslo - Corporate Compliance Insights

Fresh on the heels of the Anti-Korrupsjons+Konferansen in Norway, Richard Bistrong offers a look inside the conference and details some of the key takeaways. Originally published in Corporate Compliance Insights....more

Incorporating Employee Storytelling into Your Compliance Marketing

by Thomas Fox on

As you might suppose I read quite a bit. One of the pleasures I receive each month is when the copy of the MIT Sloan Management Review arrives. I also find the articles highly topical and present ways to consider new...more

This Week in FCPA-Episode 58, the Declination Edition

by Thomas Fox on

After last week’s guest announcers, Jay and I return for a wide-ranging discussion on some of the week’s top compliance related stories, including: 1. The first Declination of the Session’s Justice Department, Linde gas....more

FCPA Compliance Challenges & New Lines of Defense

In part one of a two part interview, Joe Spinelli, Senior Managing Director, Kroll, addresses the recent Kroll-Ethisphere Anti-Bribery and Corruption Benchmarking Report. In this interview Joe focuses on: *The need and...more

Oh, Hadn’t You Heard? You’re Violating French Law Right Now! France Gets Serieuse about Anti-Corruption

Ok, ok, don’t panic. Maybe not all of the millions of dedicated readers of this blog are in violation. Nevertheless, as of June 1, if your company does business in France, it may be time to check your anticorruption...more

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