Bribery Audits

News & Analysis as of

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

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

Pink Flamingos and the Compliance Audit

The creator of one of the most ubiquitous symbols of mid-century Americana died earlier this week. Don Featherstone, the creator of the pink plastic lawn flamingo, the ultimate symbol of American lawn kitsch, has died. He was...more

The Missing Link in Third Party Due Diligence

It is one thing to screen a third-party at the on boarding process; it is quite another to build out an entire due diligence system that screens at renewal of a third-party relationship, monitors third-party activity and...more

This Week In Securities Litigation

The Commission resolved its actions against the PRC based affiliates of five major accounting firms for failure to produce audit work papers. The settlement contains a series of procedures designed to facilitate production in...more

This Week In Securities Litigation

The Commission brought two FCPA cases this week, one of which was in conjunction with the DOJ. Both centered on the payments for gifts and travel in China. In addition, the SEC filed three manipulation cases, an action...more

Ontario Ministry of Labour Inspector Charged with Extortion

According to a Toronto Police news release, on October 21, 2014, a Ministry of Labour Inspector was arrested and charged with breach of trust, accepting a benefit from a person having dealings with government, and extortion,...more

Is Anti-Corruption a Business or Legal Issue?

On June 5, 2014, Philippe Montigny, President of Ethic Intelligence ( asks exactly that question in an editorial. My own perspective of compliance remains much along the lines of those such as Mr....more

Anti-Bribery and Corruption Compliance Practices

Compliance Week published its 2014 Anti-Bribery and Corruption Benchmarking Report, a survey of over 180 executives involved in ethics and FCPA compliance and internal audit. The Survey focused on risk, dealing with third...more

A Prescriptive Guide To Third Party Risk Management

The recent examples of compliance program credits for Morgan Stanley and Ralph Lauren have demonstrated that, more than ever, an effective compliance program can protect a company from criminal indictment and generate bottom...more

Will Independent Directors Be on the Hook for Failure of Internal Controls in FCPA Cases?

The Foreign Corrupt Practices Act ("FCPA" or "the Act") prohibits bribery of foreign public officials in order to obtain or retain business. In addition to its anti-bribery provisions, the FCPA contains accounting provisions...more

Lunch With The FCPA Compliance & Ethics Blog – Phil Wedemeyer And The Audit Perspective In Compliance

One of my weekend reading pleasures is the Saturday section in the Financial Times (FT) entitled “Lunch with the FT”. ...more

Internal Audit Review of Charitable Donations Under the FCPA

When is a rose not a rose? When it is a charitable donation not made for philanthropic purposes and it violates the Foreign Corrupt Practices Act (FCPA). I thought about that concept when reviewing the Eli Lilly and Company...more

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