Anti-Corruption Corruption

News & Analysis as of

DOJ Sharpens Focus on Corporate Compliance in Deciding Whether to Prosecute Companies

One of the factors that the U.S. Department of Justice (DOJ) considers in deciding whether to bring charges against a corporation is the existence and effectiveness of the corporation’s pre-existing compliance program. On...more

Australian Anti-Bribery & Compliance Trends

Today we welcome Ted Williams, Partner, Piper Alderman. Ted, can you share some of your background and experience? TW: Thank you, Richard, for the opportunity to engage with your community, and it was a pleasure to...more

Tackling Corruption – Now A Truly Global Initiative?

There continues to be a global drive towards greater transparency and accountability in business. There are a number of factors at play here. ...more

Homeland, Brazilian Clean Companies Act Guidance and the Need for Accurate Translations in FCPA Compliance

He used to work in the movie business so you might think the production crew of the Showtime series Homeland would just give him a call. After all he is fast becoming known as ‘the translations guy’ in the Foreign Corrupt...more

Anti-Corruption: Why Programs Fail

Today, companies around the world face daily challenges associated with corruption. This risk coupled with new laws and heightened enforcement are just a few of the factors driving companies to implement and improve...more

Layla and Other Love Songs and Risk Assessments

On this date in October 1971, Duane Allman died. He was the co-founder, along with his brother Greg, of the Allman Brothers Band. For my money he was one of the greatest guitarists of all time. At the time of his death, the...more

Focus on China - October 2015

Welcome to the third issue of Focus on China Compliance for 2015. According to the FCPA Blog’s October 2015 Corporate Investigations List, China leads the countries reported to be involved in FCPA investigations with 29...more

Building a Due Diligence Infrastructure (Part IV of IV)

A due diligence infrastructure is designed to demonstrate a company’s good faith commitment to compliance with anti-corruption laws by: identifying corruption risks; and mitigating such risks to ensure that the company does...more

New Whitepaper: Why Anti-Corruption Programs Fail: Turning Policies into Practices Launches Whitepaper Outlining Top Ten Ways Anti-Corruption Programs Fail and Insight into How to Embed Compliance across an Organization - Guidance for companies seeking to mitigate anti-corruption risks...more

A Holistic Approach to Third-Party Risk & Due Diligence

The following interview is with Leas Bachatene, CEO at ethiXbase. Hi Leas, thank you for participating in today’s Q and A. I have really enjoyed working with the ethiXbase team, including on our recent White Paper and...more

Latest Developments in Corruption Enforcement in China

The past quarter has been an active one for Chinese government enforcement activities, and the year ahead promises more of the same. Recent developments include: the strengthening of Chinese bribery laws, increased action...more

The World Bank: Lending & Developing without Corruption

The World Bank recently assessed a project relating to the funding of power stations in South Africa. The World Bank’s initial assessment appears to have cascaded from an SEC enforcement action with respect to Hitachi Ltd....more

Foreign Corrupt Practices Act 2015 Update

Despite a decline in enforcement actions by the Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the...more

Compliance at the Tipping Point, Part II – New DOJ Compliance Counsel

The second tipping point for compliance which has occurred over the last 30 days or so is the information which has leaked out that the Department of Justice (DOJ) is in the process of hiring an outside advisor to provide to...more

The SEC’s Year of FCPA Enforcement

Say what you will – the SEC is making its mark this year in FCPA enforcement. So far, the SEC has brought nine separate enforcement actions, the latest with Bristol-Myers Squibb. I am sure we will see more before the end of...more

Compliance at the Tipping Point, Part I – The Yates Memo

This is the day that the US government traditionally celebrates Columbus’ discovery of the Americas, in the form of Columbus Day. My grandfather emigrated from Italy so he always took Columbus Day as his heritage day. My...more

Bristol-Myers Squibb Pays $14 Million to SEC to Resolve China FCPA Offenses

On October 5, the SEC announced a settlement with Bristol-Myers Squibb to resolve allegations that the pharmaceutical company’s Chinese joint venture, BMS China, gave cash, jewelry, and other benefits to health care providers...more

US and China Expand Law Enforcement Cooperation

Global anti-corruption efforts continue to increase. For global companies, this trend makes compliance even more critical. One of the most significant aspects of this trend is the US government’s cooperation with China....more

The World Bank: Confronting Poverty without Corruption

I was recently reading an article about a former UN consultant who was convicted and sentenced for conspiring to inflate prices for a UN contract to distribute pharmaceuticals to the DNC. As part of the investigation, e-mail...more

HorrorFest 2015 Celebration I- The Films of Val Lewton and a Win for the DOJ

Today, October 2, is the first Friday in October so I begin my annual month of Friday HorrorFest Film highlights. This year I wanted to highlight the films of one of the great unknowns of horror films, Val Lewton. Lewton, a...more

Reflections on the Hitachi FCPA Enforcement Action

Earlier this week, the Securities and Exchange Commission (SEC) announced resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Hitachi Ltd (Hitachi). There were several interesting aspects to...more

Whistleblowing, VW’s Silence, and the Behavioural All Stars

This guest post is by Wendy Addison, Founder and Owner of SpeakOut SpeakUp Ltd. On the 2nd and 3rd of Sept 2015, I attended The International Behavioural Insights Conference in London. Hosted by the UK government’s ‘Nudge...more

The Defeat Device: Compliance and Ethics in the Auto Industry

Things are seriously bad when one of the world’s most respected business focused publications, the Financial Times (FT), asks if the auto “industry faces ‘Libor moment’”? Yet that was a headline yesterday in the lead article...more

Cleaning Up a Compliance Program Mess

You have just been hired as the new Chief Compliance Officer of a global company operating in over 80 countries, including numerous high-risk corruption countries. You have no staff and have been given a budget to hire 5...more

New DOJ Compliance Counsel: Doing Compliance Now Even More Critical

Last Friday, the FCPA Professor reported: “According to this Global Investigations Review article: “According to two people familiar with the matter, the US Department of Justice (DoJ) has hired Hui Chen, Standard...more

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