A Third Party's Perspective on Third Party Risk
Cannabis Law Now Podcast: Cannabis Companies and the Corporate Transparency Act
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
Episode 329 -- Bryn Sedlacek from Aravo on TPRM Holistic Risks and Unified Visibility
Episode 328 -- Sanctions Enforcement Risks and Redlines
Managing Corruption Risk in Latin America
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
Examining FinCEN FAQs, Proposed Legislation and Other CTA Developments
Episode 320 -- NAVEX Hotline Report -- More Reports and Higher Substantiation
The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the Justice Department Fails to Prosecute Executives'
FCPA Compliance Report: DOJ on AI and Data/Intellectual Property Protection
Episode 313 -- The Coming Criminal Corporate Sanctions Enforcement Storm
Wiley's 10 Key Trade Developments: Evolution of Export Controls
Episode 311 -- Tom Fox on FCPA Enforcement: Self Disclosure and Recidivism
Webinar: Corporate Transparency Act
Wiley’s Top 10 Trade Developments: Heightened Sanctions and Export Control Enforcement
The EU Whistleblowing Directive
Episode 304 -- Nathalie Druckmann, VP at Certa, on Artificial Intelligence Third-Party Risk Management
JONES DAY TALKS®: Corporate Compliance in Asia: Managing Rapid Regulatory Change and Ambiguity
The EU Directive for Combatting Corruption
While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement. OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions. That is quite an increase...more
Companies will often rely on a network of distributors to help sell their products in emerging markets. From a business economics standpoint, engaging a distributor is often more cost efficient than investing in a sales...more
The Walmart case, from a big picture standpoint, represents a serious warning to all global companies committed to rapid international growth. In the absence of a significant and sustained commitment to compliance, rapid...more
Believe it or not, but companies are still struggling with third-party risk management systems. I know this sounds hyper-critical but many companies continue to hang onto paper due diligence systems (sometimes with or...more
2016 was a banner year for global anti-corruption enforcement: the U.S. government set records in terms of both the number of FCPA actions brought and the total dollar amount of related fines. Meanwhile, governments from...more
On February 8, 2017, the United States Department of Justice ("DOJ") Fraud Section published a blueprint for assessing corporate compliance efforts, titled "Evaluation of Corporate Compliance Programs" ("Guidance"). It...more
Wyatt Earp died this week. Not the original Wyatt Earp who died in 1929 but the Wyatt Earp of my lifetime, who was actor Hugh O’Brian. O’Brien portrayed Earp in the long running television series Wyatt Earp which ran in the...more
In case you are not following all the latest scandals – Unaoil and the Panama Papers being two significant ones – we are seeing an evolution and possibly a revolution in due diligence expectations....more
As our previous posts illustrate, violations of the Foreign Corrupt Practices Act (“FCPA”) can carry a hefty cost. Two issues are commonly the impetus for FCPA violations and, practically speaking, pose significant FCPA...more
We all have our favorite episodes and scenes from the Seinfeld series. As we grow older, we like to reference them more and more – maybe because it reminds us of your “youth” (looking back, my 30s were certainly younger than...more
This week, I am continuing my podcast series, on the FCPA Compliance and Ethics Report, on internal controls in best practices anti-corruption compliance program, under the Foreign Corrupt Practices (FCPA), UK Bribery Act or...more
Today ends my review of what I believe to be the five steps in the management of a third party under an anti-bribery regime such as the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act. On Monday, I reviewed Step 1 –...more