News & Analysis as of

Bribery Compliance

Book Review: The Chickenshit Club

by Thomas Fox on

To my mind the most significant and important book that every Chief Compliance Officer (CCO), General Counsel (GC) and compliance practitioner needs to read is The Chickenshit Club by Pulitzer Prize winning journalist Jesse...more

Dorsey Anti-Corruption Digest - September 2017

by Dorsey & Whitney LLP on

Keeping ahead of global anti-corruption trends is critical in today’s business markets. The Dorsey Anti-Corruption Digest, which puts global trends at your fingertips, puts you ahead. The deep experience of the Dorsey...more

The Objective of Due Diligence: To Protect Your Culture

by Michael Volkov on

There has been so much attention paid to due diligence. We have reams and reams of articles highlighting the importance of due diligence. In addition, numerous vendors of due diligence services and technologies fill the...more

Tales from the Corporate Scandal Crypt: GM, VimpelCom, VW and Wells Fargo

by Michael Volkov on

We are fascinated by corporate scandals. Since the 1980s, the US public has enjoyed unraveling corporate scandals, and vilifying corporate leaders caught in the web of deceit and misconduct. I am sure there are historical...more

Foreign Corrupt Practices Act 2017 Mid-Year Update

by BakerHostetler on

The first half of 2017 has been eagerly anticipated following the record-setting year in 2016 for Foreign Corrupt Practices Act (“FCPA”) enforcement by both the U.S. Department of Justice (“DOJ”) and the U.S. Securities and...more

Hurricane Harvey – Reflections on Being Prepared

by Thomas Fox on

We are now half way (hopefully) through what is predicted to be the largest amount of rain seen in one week by the city of Houston and its surrounding environs in the city’s recorded history. First and foremost, my deepest...more

Anti-Corruption Risks and Drug and Device Companies

by Michael Volkov on

For years, the Justice Department and the Securities and Exchange Commission touted the FCPA “sweep” of the pharmaceutical and medical device industries. With good reason, DOJ and the SEC turned the drug and medical device...more

DOJ Announces Enhanced Enforcement of Healthcare FCPA Compliance

by Holland & Knight LLP on

The Department of Justice’s (DOJ) Criminal Fraud Section announced a new partnership between DOJ’s Healthcare Fraud Unit’s Corporate Strike Force and Foreign Corrupt Practices Act (FCPA) prosecutors. The partnership is meant...more

New FASB Revenue Recognition Standard-Revenue from Contracts with Customer

by Thomas Fox on

We are now less than six months away from a new Revenue Recognition standard which may significantly impact the compliance profession, compliance programs and compliance practitioners going forward....more

Dorsey Anti-Corruption Digest - August 2017

by Dorsey & Whitney LLP on

The Department of Justice (DOJ) ended its probe of Net1 UEPS Technologies, according to SEC filings from the South African-based payment processing company. The company received a declination from the Securities and Exchange...more

Compliance and the Noble Fight Against Corruption

by Thomas Fox on

In two recent public appearances, Department of Justice (DOJ) representatives spoke to issues of concern to every compliance practitioner regarding one role of the DOJ going forward and how that role will continue to feed the...more

Anti-Corruption Compliance: The Need to Look Under the Cloak of Materiality

by Michael Volkov on

Sarbanes-Oxley revolutionized the auditing profession. Section 404 imposed stringent requirements for disclosure of the state of a company’s internal controls and financial reporting. The company’s independent auditor is...more

White Collar Watch (July 2017 • Vol 1, Issue 2)

by Blank Rome LLP on

Welcome to the summer edition of Blank Rome’s White Collar Watch. In a world that seems to bring new challenges daily—such as the global cybersecurity attacks that were launched in late June—this newsletter is designed to...more

FCPA under the New Administration

by Blank Rome LLP on

The single most frequently asked question by our international clients over the past several months is whether there will be changes in white collar prosecution priorities under the new administration, specifically with...more

New Revenue Recognition Standard – Part VI: What Does Mean?

by Thomas Fox on

Over several blog posts, I have explored in detail the new Financial Accounting Standards Board (FASB) Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), which set forth a new Revenue...more

Important Polling Results from BVD Webinar on Beneficial Ownership

by Michael Volkov on

On July 5, 2017, Bureau Van Dijk, a sponsor of my blog, conducted a webinar on the importance of beneficial ownership information to corporate compliance functions....more

2nd Circuit Weighs in on Certifying Classes Involving Foreign Securities

by Burr & Forman on

In In re Petrobras Securities Litigation, the Second Circuit Court of Appeals recently issued an opinion regarding the standards for certifying a class involving foreign securities. Petrobras is a multinational Brazilian gas...more

New Revenue Recognition Standard – Part V: Allocation and Revenue Recognition

by Thomas Fox on

I continue to explore the Financial Accounting Standards Board (FASB) issued Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), for public business entities, certain not-for-profit...more

New Revenue Recognition Standard – Part IV: Determining the Transaction Price

by Thomas Fox on

This week I am exploring the Financial Accounting Standards Board (FASB) issued Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), for public business entities, certain not-for-profit...more

New Revenue Recognition Standard – Part III: Performance Obligations

by Thomas Fox on

This week I am exploring the Financial Accounting Standards Board (FASB) issued Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), for public business entities, certain not-for-profit...more

New Revenue Recognition Standard – Part II: Contracts

by Thomas Fox on

This week I am exploring the Financial Accounting Standards Board (FASB) issued Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), for public business entities, certain not-for-profit...more

“Too Important to Jail,” the Yates Memorandum and FCPA Criminal Prosecutions

by Michael Volkov on

The Justice Department’s continuing lack of individual criminal prosecutions in the FCPA arena continues to raise serious questions. DOJ’s issuance of the Yates memorandum was seen as a new and important reiteration of DOJ’s...more

Anti-Corruption Digest - July 2017

by Dorsey & Whitney LLP on

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. The Digest puts material regarding anti-corruption enforcement from around the world at your fingertips, keeping you ahead of critical events that impact global...more

Trump and Compliance: The First 100 Days [eBook]

by Thomas Fox on

Since November 9, 2016 the Apocalypse has not descended (at least as of the writing of this foreword). Since that time many of the leading compliance commentators have considered what the first 100 days of the Trump...more

Hui Chen-Propelling a New Level of Thinking on Compliance

by Thomas Fox on

Last week Matt Kelly scored the first interview with the Department of Justice’s (DOJ) former Compliance Counsel, Hui Chen after she left the DOJ. Kelly posted it on his Radical Compliance podcast site and its available on...more

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