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Code of Conduct, Compliance Policies and Procedures-Part I

For the remainder of this week, I will have a four-part episode on your Code of Conduct and anti-corruption compliance policies and procedures. In today’s post I will review the underlying legal and statutory basis for the...more

GSK Faces a Bad Day at Black Rock

One of my favorite movies is Bad Day at Black Rock. It is one of the few movies to combine elements of film noir into something approaching a traditional Western. It also attacks directly the prejudice and hate against...more

The FCPA Person Of The Year – The Prosecutor

To continue a “tradition” on Corruption Crime and Compliance, I like to end the year with recognition of the “person of the year,” referring to the institution which has had the most impact in the enforcement and compliance...more

FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions [Video]

In this episode, I review the corporate FCPA enforcement actions of 2013. ...more

Global Anti-Corruption Enforcement And Emerging Practical Issues

As global enforcement becomes a reality, companies face a unique set of risks which can be mind-numbing in complications. With the long-arm reach of the FCPA, UK Bribery Act and other anti-corruption laws, more enforcement...more

FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2 [Video]

This episode 30 is Part 2 of my interview with the FCPA Professor. ...more

It’s The Great Pumpkin: Lessons In Process Validation And Oversight

Today is Halloween and we celebrate the greatest Halloween cartoon in the history of the world, ever, “It’s the Great Pumpkin, Charlie Brown”, which premiered in 1966. As usual, the story revolves around the Peanuts gang, who...more

Return To The Baker’s Dozen In A Best Practices Compliance Program – Total Part II

Yesterday I reviewed the facts surround Total SA’s (Total) lengthy bribery scheme to win contracts in Iran....more

Distributors Should Be Analyzed As Any Other Third Party Representative in the Sales Chain

Ed. Note-David Simon is a partner at Foley and Lardner and Bill Athanas is a partner at Waller Lansden Dortch & Davis, LLP. Both have practices which include FCPA compliance. After my recent post on distributors under the...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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