Anti-Corruption The Foreign Corrupt Practices Act

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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 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

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

FinCrimes Update - April 2016 Summary, Volume 4, Issue 4

AML/BSA & OFAC: FINCEN ANNOUNCES DEPARTURE OF DIRECTOR CALVERY - On April 26, FinCEN announced the departure of Director Calvery. Commenting on Calvery’s accomplishments during her tenure as Director, the agency...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

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

China Aims to Strengthen Regulations on Commercial Bribery

Recently, the Legal Affairs Office of the State Council released draft amendments (Draft Amendments) to the Anti-Unfair Competition Law (AUCL) of the People’s Republic of China (PRC) for public comments. The Draft Amendments...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

The Art of Self Defense

Corporate compliance programs come in all shapes and sizes and apply whether your company is privately owned or publicly traded. These internal controls take the form of accounting and audit procedures,...more

BP, Executive Pay and the Surfin’ Bird

Surf music is certainly an under-rated rock and roll genre. One of my favorites is The Trashmen’s Surfin’ Bird. It reached Number 4 on the Billboard Chart in 1963. I happened to hear it recently when I was reading about some...more

Tackling Market Abuse And Corruption — Finally

In the next few weeks, the French Minister of Finance should present to the Government a Bill which would, if adopted, reform the French regime on market abuse, create a new anti-corruption agency and impose an obligation on...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

Are Your Company’s Legal, Due-Diligence, De-risking, or Compliance Obligations Impacted by the “Panama Papers”?

In an unprecedented event earlier this week, 11.5 million files from the Panamanian law firm Mossack Fonseca were allegedly leaked. Assuming they are genuine, as appears to be the case, these “Panama Papers” offer a...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

New DOJ Guidance and FCPA Pilot Program, Part I-Introduction

Last week the Department of Justice (DOJ) held a Press Conference, open to all, led by Andrew Weissmann and Leslie Caldwell. At this Press Conference, they announced the culmination of several ongoing initiatives into a new...more

Historic FCPA Settlement Reflects Increased Regulatory Focus on International Anticorruption Issues Arising from M&A Transactions

Most employers already know that violating the Foreign Corrupt Practices Act of 1977 (FCPA) has serious consequences, including significant fines. Those potential fines just got even heavier. On February 18, 2016, the U.S....more

US CHINA TRADE WAR–Trump, Trade Policy, NME, TPP, Trade, Customs, False Claims, Products Liability, Antitrust and Securities

Dear Friends, After returning from a two week trip to China to work on the Solar Cells case, this March blog post will cover trade policy, including Trump’s impact on Trade Policy, trade, Customs, False Claims Act, the...more

Nordion: A Contrast in FCPA Enforcement Actions

FCPA enforcement actions run the gamut of fact patterns and structured resolutions. We are in the midst of a transformation in the overall settlement environment with an expected increase in individual prosecutions....more

Thoughts from the SCCE Utilities & Energy Compliance & Ethics Conference

Ed. Note-today we have a guest post from Mike Snyder of TRACE International (and noted Aggie) on his observations from the recently concluded SCCE Utilities and Energy Conference. I recently attended the SCCE Utilities...more

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