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Bribery & Deterrence: A Tale of Two Sentences

In an August 11, 2014 article (www.thebirberyact.com) “Supersize me: Innospec 4 sentencing remarks do much more than they say on the tin,” Barry Vitou &? Richard Kovalevsky (“The Authors”) do a great service by elevating the...more

How Can Global Corporations Afford (or Afford Not) To Employ Professional Language Solution Providers

It seems like a daily occurrence that news organizations and blogs (this one included) report that global corporation XYZ, Inc. has run afoul of FCPA statutes somewhere in the world. The next few paragraphs will recount the...more

Did Bernie Ecclestone Skip Anti Bribery Training?

It astonishes me how many cases there are of wealthy individuals simply buying their way out of trouble. Let’s face it, in the world we live in today, money still talks, even in courts of law. Maybe this mentality was...more

Company Agrees to $6.8 Million Fine For Selling Tainted Eggs and Bribing Official

While foreign bribery makes for sensational headlines, a Midwest egg company recently discovered why U.S. enforcement actions for domestic bribery have resulted in a sharp increase in corporate fines. The egg company agreed...more

Corruption, Regime Change & Risk

Recently, I have been reading and blogging on a number of different papers, guides and articles that deal with the challenges of foreign bribery and third party intermediaries. While each work has been interesting, compelling...more

Does Your Company Still Allow Facilitation Payments?

One of the more confusing areas of the US Foreign Corrupt Practices Act (FCPA) is in that of facilitation payments. Facilitation payments are small bribes but make no mistake about it, they are bribes....more

What happens when business strategy becomes a red-flag for bribery?

Richard Bistrong spent much of his career as an international sales executive. He was the Vice President of International Sales for a large, publicly traded manufacturer of police and military equipment, which included...more

Nixon Announces Resignation; GSK Just Resigns

Next week, Shanghai’s No. 1 Intermediate People’s Court is scheduled to open a trial against Peter William Humphrey, a 58-year-old British national, and his wife, Yu Yingzeng, a 61-year-old American, on charges of illegally...more

“Countering Small Bribes.” A Personal Perspective on the Guidance by Transparency International

First, whenever I read a paper, book or guidance about “how to pay a bribe,” or “how to avoid a bribe,” etc., it is always with some degree of skepticism. I often wonder how an organization or person can have a perspective...more

Corruption & Procurement: Bribery "Thrives in the Dark."

In the July 31, 2014 edition of the Jakarta Post there was a featured article “Smith & Wesson bribery scandal involves National Police officers,” which reported that “the Indonesian Corruption Watch (ICW) has called for an...more

Is Anti-Corruption a Business or Legal Issue?

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

Rationalizing Bribery: Corruption Has No Witness.

This is part three of my four part series on how I "Rationalized Bribery." It addresses the reality that there are usually no witnesses to overseas discussions involving an actual or potentially corrupt transaction....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

Rationalizing Risk: Compliance as "Bonus Prevention"

As part of my series on “Rationalizing Bribery,” I now turn to the issue of personal incentive compensation. As tweeted by Ben DiPietro, @BenDiPietro1, Wall Street Journal Reporter, during my interview at the Dow Jones Global...more

Looking Back on Johnny Winter and GSK’s 2001 China Bribery Scandal

Interestingly, there was an article in the Financial Times (FT) by Demetri Sevastopulo and Andrew Ward, entitled “GSK admits to 2001 Chinese bribery scandal”, which reported that the UK pharmaceutical company GlaxoSmithKline...more

FCPA Compliance and Ethics Report-Episode 77World Cup Report-Part VII, with Mike Brown [Video]

In this episode of the FCPA Compliance and Ethics Report, Mike Brown and I conclude our World Cup Report series. We continue our look at some of the compliance and ethics lessons from the recently concluded World Cup. ...more

How To Pay A Bribe: Solutions that Explode

Over the past few weeks I have had a chance to read How To Pay A Bribe, Thinking Like a Criminal to Thwart Bribery Schemes (2014, edited by Alexandra Wrage, Seven Wirz), and while I have enjoyed a number of the chapters,...more

The UK Bribery Act, Three Years On: Can We Relax Yet?

The Bribery Act 2010 has now been in force for three years. Despite the announcements and commentary that it heralded a new and aggressive face toward corporate corruption, there have as yet been no corporate prosecutions...more

Japan Discloses New Efforts to Combat Foreign Bribery, as OECD Steps Up Pressure on Japan to Increase Enforcement

While many people don’t know it, a bribery scandal in Japan in 1976 was part of the motivation for the Foreign Corrupt Practices Act (FCPA), which was signed into law on December 19, 1977. Almost exactly two decades later,...more

Firms Charged with Both Bribery and Financial Crime Hit Hardest by FCPA Enforcement

Although passed in 1977, the Foreign Corrupt Practices Act (FCPA) was not significantly enforced until 2005. Since then, the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have made up for the...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

12 Tips for an Effective Due Diligence Program for Third Parties

In an evolving global economy, expanding business opportunities often lead to more complex supply channels and business relationships that can increase corruption risks and burden efforts to comply with the applicable laws...more

FCPA Compliance and Ethics Report-Episode 65-World Cup Report-Part I [Video]

The FCPA Compliance and Ethics Report, Episode 65 is out. In this episode, I begin a 4 part World Cup series with Mike Brown, Managing Director of Infortal. In this episode we discuss bribery and corruption of referees and...more

Anti-Corruption Digest

Anti-Corruption Digest is an update distributed on a monthly basis by Dorsey & Whitney providing a summary of the latest developments in anti-corruption enforcement activity around the world. In This Issue: -...more

May Flowers for GSK? The Corruption Investigation Deepens

April showers bring May flowers, at least that is the old truism. One place it is decidedly correct is at the RHS Chelsea Flower Show, which began its run as one of the, if not the greatest, annual flower shows in the world...more

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