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Anti-Corruption Due Diligence Corruption

Trends from 2016 Record FCPA Enforcement Year (Part II of III)

by Michael Volkov on

No matter how you cut it – this was a big year in FCPA enforcement. Not just because of the large enforcement actions but the scope and depth of enforcement, remediation and compliance program demands....more

New French Anticorruption Legislation Affecting Large French and Foreign Groups of Companies and Their Top Management

On December 9th, 2016, France officially enacted the Law on transparency, anti-corruption and economic modernization (so-called "Sapin II bill") which introduces the following key changes...more

Third Party Risk Management Not Just Due Diligence

by Michael Volkov on

The term “due diligence” is an overused expression in the compliance world. It has become a term to mean heightened concern or investigation. No one can really define what it means except to say it has different meanings in...more

Corruption Risks and Corporate Social Responsibility Spending

by Michael Volkov on

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

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

Building a Due Diligence Infrastructure (Part IV of IV)

by Michael Volkov on

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

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

Farewell to Chocolate Thunder, Baylor Football and Due Diligence

by Thomas Fox on

Daryl Dawkins died yesterday. To anyone who followed the National Basketball League (NBA); Dawkins will always be remembered with the brilliant Stevie Wonder-derived moniker – Chocolate Thunder. I will also remember him for...more

The Looting Machine & The Modernization of Corruption

Today’ Q and A is with Tom Burgis, Investigations Correspondent at Financial Times and author of “The Looting Machine: Warlords, Oligarchs, Corporations, Smugglers, and the Theft of Africa’s Wealth”. As Tom States in his...more

5 Signs Your Anti-Corruption Compliance Program is Suffering from “Tunnel Vision”

by Michael Volkov on

Many companies, depending on the industry, have implemented anti-corruption compliance programs. Some of the programs meet the standard for an “effective” anti-corruption compliance program. There is a vast difference between...more

Cecil the Lion and Due Diligence Failures

by Michael Volkov on

The “I didn’t know” defense is a tough one to sustain. Maybe you didn’t “know,” but should you have known? Were all the signs there but you looked the other way? Should you have asked more questions? Is it fair to infer by...more

Private Equity’s Corruption Risk Underbelly — Portfolio Companies

by Michael Volkov on

FCPA enforcement will likely take a turn into the private equity industry. I know this is a regular claim by FCPA practitioners but we already can see the beginning of the trend. The “princeling” investigations are...more

How to Succeed in Africa by Choosing Partnership over Corruption

Big opportunities for exporters in Africa - There is no doubt that the continent of Africa is a land rich in opportunities for international businesses. With an abundance of natural resources, some of the world’s fastest...more

Great Structures Week V – The Tacoma Narrow Bridge Failure and Preventing Failure in Your Compliance Program

by Thomas Fox on

I conclude my Great Structures Week with a focus on structural engineering failures: suspension bridges and the challenges of wind in their construction and maintenance. I am drawing these posts from The Great Courses...more

More Than Due Diligence: Never-Ending Due Diligence

by Michael Volkov on

Due diligence of third parties can drive you crazy. You know you are in trouble when you start babbling to yourself and others about red flags, more red flags, and even more red flags....more

Anti-Corruption Due Diligence Practical Steps to Protect Your Company from Third Party Risks

by Michael Volkov on

Almost every FCPA enforcement action involves misconduct by third party agents and distributors. The Justice Department and the SEC have emphasized the importance of companies conducing appropriate due diligence. In the...more

Benchmarking Bribery and Corruption: "Vet it and forget it."

On my own "must read" stack has been sitting the "2014 Anti-Bribery and Corruption Benchmarking Report, Untangling the Web of Risk and Compliance," ("ABC Report") by Kroll and Compliance Week. While I have read a multitude...more

Managing And Minimizing Your Third-Party Risks

by Michael Volkov on

Let’s start with a few basic assumptions – we all know that third parties are often the most significant risk for corruption. ...more

Preventing Corruption While Protecting Personal Information

by Morrison & Foerster LLP on

Multinational businesses are subject to a patchwork of laws of the various jurisdictions in which they operate. Complying with the myriad rules and regulations can be challenging. Compliance obligations vary from one country...more

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