News & Analysis as of

Goodyear FCPA Fine Highlights Benefits of Cooperation and Robust Compliance Controls

The Goodyear Tire & Rubber Company (“Goodyear”), one of the world’s largest tire companies, reached a significant settlement with the U.S. Securities & Exchange Commission (“SEC”) in connection with charges that two of its...more

Bribery and Compliance in India: Know the Challenge and Prepare for It

Today I welcome Sherbir Panag, for another post in my series of country discussions, where we will address Bribery and Anti-Bribery Compliance in India. As a forward, this was an interesting engagement, as it provided me...more

This Week In Securities Litigation

Four SEC Commissioners addressed the annual SEC Speaks Conference, reviewing recent agency initiatives and tracing potential paths for the future. The SEC also brought another FCPA action, a misappropriation case and an...more

Goodyear Settles SEC FCPA Charges

Goodyear Tire and Rubber Company settled FCPA books and records and internal control charges with the SEC. The settlement reflects the extensive cooperation and remedial efforts of the company. In the Matter of Goodyear Tire...more

Goodyear’s Settlement with the SEC Emphasizes the Importance of FCPA Due Diligence in M&A Transactions and of Having a Robust...

On February 24, 2015, Goodyear Tire & Rubber Co. agreed to pay more than $16 million to settle charges that two of its subsidiaries allegedly paid $3.2 million in bribes that generated $14,122,535 in illicit profits. The SEC...more

Anti-Bribery Compliance in Canada: An Interview with Kristine Robidoux

Today we welcome Kristine Robidoux, Partner, Gowlings, for a view of anti-bribery and compliance issues from Canada. RB: Hello Kristine, thank you for joining me in today’s interview, as we try to share some of the...more

Bone-headed Moves on the Football Field and Idiotic Statements About Corruption

That football truism (allegedly) came from former Texas Longhorn head coach Darrell Royal. While he intoned it in a different era, Pete Carroll and his Seattle Seahawks proved it still to be valid in the most recent Super...more

A Most Violent Year – Doing What is Most Right

It is rare to say but Hollywood occasionally can provide us with ethics and compliance lessons. My wife and I recently saw the movie, A Most Violent Year. It is worth seeing – not just for entertainment, but also for the...more

FCPA Compliance and Ethics Report-Episode 130, The Oscars and Compliance, Part IV with Jay Rosen [Video]

In this Part IV of my continued exploration of the Oscars and compliance with Jay Rosen, we look at the touchpoint which Hollywood and the movie industry has which might subject it to FCPA liability. ...more

Q & A with Sarah Chayes: Author, “Thieves of State.” The ‘Odorless Gas’ of Corruption.

Today is part II of my interview with Sarah Chayes, Author, Thieves of State, Why Corruption: Threatens Global Security. This week I am particularly excited about my post, as on Tuesday, February 10th, I will have the...more

"United States: International Cooperation, Anti-Corruption and Tax Remain Key Issues for Enforcement Authorities"

U.S. authorities continue to aggressively pursue cross-border investigations and to scrutinize closely the compliance programs of multinational corporations. Investigative activity by U.S. authorities in 2014 was particularly...more

Corruption, Compliance & Criminal Regimes: An Interview with Sarah Chayes

Sarah, thank you kindly for participating in this Q and A. I call readers’ attention to your new book Thieves of State, Why Corruption: Threatens Global Security. Today will be part I of our II part interview....more

FCPA Compliance and Ethics Report-Episode 124, The Oscars and Compliance, Part I with Jay Rosen [Video]

In this episode I begin a five-part series on the Oscars and Compliance with recovering Hollywood screenwriter Jay Rosen. In this Part I, we review the process by which films are nominated for the Oscars and the campaigns...more

FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras [Video]

In this episode, Compliance Week Editor-in-Chief Matt Kelly and I discuss the Avon and Alstom FCPA enforcement actions and then take a look at the ongoing Petrobras corruption scandal and what it means for Brazil. ...more

2015 Trends: #5 Regulatory Enforcement Moves Down Market

While ethics and compliance scandals that implicate brand name companies tend to grab the headlines, smaller organizations have always borne the brunt of regulatory enforcement. Over the years, U.S. Sentencing Commission data...more

FCPA Compliance and Ethics Report-Episode 121-FCPA Year in Review, Part II [Video]

In this episode I review the two Opinion Releases, Esquenazi court decision, DOJ communications via speeches on FCPA enforcement. I end with a look at 2015. ...more

OECD Foreign Bribery Report: Leveraging The How, Where And Why Of Bribery To Bolster Your Ethics And Compliance Training Program

In my last blog post, “The OECD Foreign Bribery Report: 7 Insights To Improve Your Ethics And Compliance Training Program,” I identified the seven bribery trends covered in OECD’s Foreign Bribery Report. The report listed...more

The Compliance Advantage in Mexico

A View from the Front-Lines of Compliance in Mexico - Today, I am pleased to welcome Patrick Henz as a guest contributor. Patrick started his career in Compliance at the end of 2007, when he was responsible for the...more

FCPA Compliance and Ethics Report-Episode 118-the Alstom FCPA Enforcement Action [Video]

In this episode 118, I take a deep dive into the Alstom FCPA enforcement action and its implication for the CCO and compliance practitioner. I also discuss comments from Dick Cassin and the FCPA Professor on the case. ...more

FCPA Compliance and Ethics Report-Episode 117-the Avon FCPA Enforcement Action [Video]

In this episode I take a deep dive into the recent concluded Avon FCPA enforcement action. ...more

The OECD Foreign Bribery Report: 7 Insights to Improve Your Ethics And Compliance Training Program

According to Ernst and Young’s ‘Navigating today’s complex business risks Europe, Middle East, India and Africa Fraud Survey 2013,’ half of workers surveyed across Europe, the Middle East, Africa and India believe bribery and...more

The Avon FCPA Settlement – Part III

Today I conclude my 2014 blog posts with a final look at the Avon Foreign Corrupt Practices Act (FCPA) enforcement action. Before getting to the key lessons that a compliance practitioner may draw from this enforcement...more

Bribery and Business Attitudes

Alison Taylor, Senior Managing Director, Control Risks, in a white paper, “Risk, An Organizational Perspective,” states “the traditional preventative approach to risk management is proving inadequate in the face of regulatory...more

The OECD Foreign Bribery Report: ‘Too Big to Debar’

“Your criminal actions raise serious questions as to whether you have the requisite personal integrity and business ethics to be a responsible Government contractor.” That’s me. I was debarred from being a government...more

Shoring Up Your Internal Controls to Keep Your FCPA Compliance Program Current

We recently hosted a webinar featuring noted FCPA expert Tom Fox. Tom explained exactly what the DOJ and SEC look for when enforcing the FCPA and how organizations can stay within the FCPA regulations. Jimmy Lin, our VP of...more

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