Anti-Corruption Compliance

News & Analysis as of

Compliance Training – Part II: Risk Ranking and Design

Yesterday I began what I thought would be a two-part series on compliance training.However, or perhaps more accurately, as usual, I got carried away so I am now off on a multi-part series on how to design, implement and...more

Be Fully Compliant, and Avoid Lawsuits!

Who could dislike the title of this post? It promises to solve all your compliance problems and keep your business out of litigation. Were it only that simple. Of course, it is not. But, when it comes to compliance,...more

Lie to Win or Be Honest and Lose? When Ethics Can Cost You

What would you do? In this classic situation, all the elements for staying the course rather than disclosing the truth are present and the question is: should you tell on yourself? Ellen Hunt sets forth the dilemma that we...more

Can you teach anti-corruption?

The following interview is with Elena Helmer, Director, Master in Anti-Corruption Studies (MACS) Programme, International Anti-Corruption Academy (IACA). Q: Elena, you are director of IACA’s Master in Anti-Corruption...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

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

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

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

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

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

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

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

Panama Papers Scandal Puts Third Party Risk in Focus

The Panama Papers scandal should serve as a wake-up call for every organization—and it should prompt compliance officers to closely scrutinize the third party vendors they do business with. ...more

Panel Offers Insights on Doing Business in Colombia

As Colombia moves toward a peace agreement with FARC rebels and works to accomplish reforms necessary for OECD accession, the nation stands poised at the threshold of significant growth and transformation. Such was the...more

Dick Cassin: ‘The FCPA Should Win the Nobel Peace Prize’

“Richard L. Cassin” is one of the best-known bylines in the compliance field. He’s been called the Dean of the compliance bloggers. He founded the FCPA Blog almost nine years ago. Incredibly, he has personally written...more

Dorsey Anti-Corruption Digest - April 2016

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more

The DOJ’s Self-Disclosure Program Is Not Even Half the Story

Lots of people are talking about the DOJ’s new self-disclosure pilot program, but it was only the last of three steps announced in the DOJ’s Fraud Section FCPA Enforcement Plan and Guidance. One of them has the potential to...more

French Anti-Corruption Reform Expected In 2016

France to introduce significant changes affecting large companies and top management, to improve current anti-bribery system. The French Parliament is expected to enact “Sapin II” on transparency, anti-corruption and...more

Top Ten International Anti-Corruption Developments for March 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

Big Data in a Best Practices Compliance Program, Part I

I have founded several podcasts, one of which is Compliance into the Weeds, where Matt Kelly joins me each week take a deep dive into the weeds of a compliance related topic. As many of you know, Kelly is the former...more

Anti-Bribery and Compliance Challenges Ahead [Video]

In this short video, Richard Fenning, CEO, Control Risks, shares his reflections on the 2016 Control Risks “International Business Attitudes To Corruption Survey” which is available on the Control Risks website. In the...more

5 Ways Training on Your Compliance Policies Can Protect Your Organization

We write a lot about the importance of creating, implementing and managing the right policies. But implementation is only half the battle. If you don’t give your employees thorough, effective and regular training on them, you...more

New and Important Compliance Standards in DOJ’s Recent FCPA Guidance (Part II of II)

The importance of DOJ’s hiring of Hui Chen as Compliance Counsel was recently confirmed by DOJ’s release of new compliance remediation standards for FCPA compliance programs. DOJ has, once again, raised the bar on FCPA...more

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