Bribery Compliance

News & Analysis as of

Anti-bribery compliance in India: Both sword and shield

In recent years, both the United States Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have stepped up their enforcement of the Foreign Corrupt Practices Act (FCPA), including to address...more

Anti-Corruption Enforcement Has Gone International

Matt Stephenson, myself and others have engaged in a dialogue about where Foreign Corrupt Practices Act (FCPA) enforcement may be headed under the incoming administration. I have tried to focus on why compliance with...more

Coordinating Third Party Due Diligence and Procurement

Third party risk management is easily one of the most challenging risks for compliance officers. With all the attention and hype surrounding third party risk, companies have marshaled attention and resources to mitigate the...more

Sapin II Law: The Modernization of France's Fight Against Corruption

After years of facing international criticism for purported “laxity” towards transparency and the fight against bribery and corruption, France has adopted new legislation aiming to rectify this deficiency, which imposes...more

Aggressive Remediation: Embraer and JP Morgan

There is no question that the Justice Department has raised compliance program expectations in a number of areas. Whatever you may think about the efficacy or fairness of the FCPA Pilot Program, the Justice Department has...more

New Rule: The Fight Against Corruption Speaks French

On November 8, France adopted its new framework legislation against corruption, the Law on Transparency, the Fight against Corruption and Modernization of Economic Life, otherwise called the “Sapin II Law” from the name of...more

Why FCPA Compliance Makes America Great

Last week, a colleague asked me what I thought the Trump administration might hold for Foreign Corrupt Practices Act (FCPA) enforcement specifically and for the greater compliance discipline in general. I have been exploring...more

Hunter S. Thompson and the World of International Corruption

In a tale worthy of the famous Hunter S. Thompson maxim, that “When the going gets weird, the weird turn pro”; the tale of BSG Resources (BSGR) and the Simandou mining concession in Guinea took a very weird turn this week...more

When Leslie Caldwell Talks FCPA, You Should Listen

November begins the final push for the compliance conference season, which customarily ends with the ACI National FCPA Conference. During November and into early December, Department of Justice (DOJ) officials have...more

AAG Caldwell Touts Success of FCPA Enforcement and Pilot Program

In a speech last week, Criminal Division Assistant Attorney General Leslie Caldwell touted the success of the FCPA Pilot Program. AAG Caldwell outlined the success of the FCPA enforcement program, listing many of the...more

Rethinking Stakeholder Engagement for the New Millennium – Part II

This week, I began a two-part series based upon recent Research Report (Report) issued by BSR entitled “The Future of Stakeholder Engagement”, authored by Sara Enright and Alison Taylor, with additional guidance and insights...more

ISO 37001: Why Your Anti-Corruption Policy Needs to Go Global

Ten years ago the standard anticorruption policy was nearly exclusively FCPA-focused. DOJ and SEC enforcement actions were the primary, if not the only, concern for corporate executives and board members. The UK Bribery Act...more

When Lawyers Cross the Line – Breaking Bad Under the Law

While reading the Embraer settlement documents, I read over the facts implicating a senior legal executive and his/her involvement in the Embraer bribery scheme. Truthfully, I had a slight gasp as I read about a fellow lawyer...more

Lessons Learned from Embraer $205 Million FCPA Settlement (Part II of II)

The Embraer FCPA settlement action contains a number of important lessons learned and compliance reminders. In several significant respects, the Embraer case confirms in several areas why proactive compliance programs are...more

Embraer Finally Lands $205 Million FCPA Settlement (Part I of II)

After years of investigation, disclosures, and press reports, the Embraer FCPA case finally came to a close. Hopefully, we will not see more of these long-term, seemingly endless investigations. The Justice Department and the...more

FCPA Enforcement Action Highlights Risks for the Financial Services Industry and Individual Executives

New York-based hedge fund Och-Ziff Capital Management Group (the “Hedge Fund”) agreed to pay approximately $412 million to resolve charges brought by the U.S. Securities and Exchange Commission (“SEC”) and Department of...more

Embraer FCPA Enforcement Action – Part IV

I conclude my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the resolution of...more

Embraer FCPA Enforcement Action – Part III

Today I continue my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the...more

Embraer FCPA Enforcement Action – Part II

Today I continue my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the...more

Embraer FCPA Enforcement Action, Part I

The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) continued their stunning 2016 run of Foreign Corrupt Practices Act (FCPA) decisions with the announcement of the resolution of the Embraer SA...more

Gearing Compliance to the Tasks at Hand

I recently had the opportunity to travel to Chicago for my first SCCE Compliance and Ethics Institute (CEI), and attended a session “Keeping Compliance Simple,” which was led by Ricardo Pellafone, CEO, The Broadcat...more

Landmark SEC Decision Cites Compliance, Diligence in Decision Not to Prosecute FCPA Violations

In a remarkable affirmation of the value of robust compliance and due-diligence programs, the Securities and Exchange Commission last month announced that it would not prosecute a U.S. company for potential violations of the...more

Och-Ziff: Accountability and Internal Controls (Part IV)

There are a number of important lessons from the Och-Ziff enforcement action, some of which are related to the private equity and hedge fund industry and some of which apply across all businesses....more

FCPA Enforcement Ramping Up Against Private Equity and Hedge Funds (Part III)

The Och-Ziff settlement has now set the stage for the Justice Department and the SEC to focus its enforcement eye on the private equity and hedge fund industry. The Och-Ziff action was initiated in response to the SEC’s...more

John Fogarty Rocks-Nu Skin Informs Oversight

I recently saw John Fogerty in concert. For those you are not aware, he was a founding member and the driving force behind Creedence Clearwater Revival (CCR), one of the very top American groups from the 1960s and early...more

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