Bribery Corruption

News & Analysis as of

Is the DOJ’s New FCPA Pilot Program an Offer You Can’t Refuse?

Earlier this month, Assistant US Attorney Leslie Caldwell announced that the US Department of Justice’s Criminal Division Fraud Section will try to entice companies to self-report potential FCPA issues. The DOJ included...more

Mike Duffy Acquittal Sheds Light on Criminal Code Corruption Offences

Last week’s acquittal of Senator Mike Duffy on fraud, corruption and bribery offences shows Ontario courts will not find “corrupt” intent lightly. The decision underscores the importance of subjective criminal intent in...more

DOJ Criminal Division Launches One-Year Pilot Program as Part of Enhanced FCPA Enforcement Strategy

On April 5, 2016, the Department of Justice (“DOJ”) Criminal Division’s Fraud Section released a memorandum setting out “three steps” in its “enhanced” enforcement of the Foreign Corrupt Practices Act (“FCPA”). See Apr. 5,...more

New DOJ Guidance and FCPA Pilot Program – Part III: Ongoing Remediation

I continue my exploration of the implications from the Department of Justice (DOJ) announcement last week of a new program around Foreign Corrupt Practices Act (FPCA) enforcement, the “Pilot Program”. Contemporaneously, the...more

FinCrimes Update - March 2016 Summary, Volume 4, Issue 3

BREAKING NEWS: PANAMA PAPERS: IMPLICATIONS FOR FINANCIAL CRIMES COMPLIANCE PROFESSIONALS - A group of international news outlets published a series of articles this week regarding the so-called “Panama Papers;” 11.5...more

Bribes and the remedy of Tracing

Relations between companies and businessmen worldwide are often governed by contracts subject to English law. Bribery is – regrettably – common in worldwide business. A discussion as to how English civil law treats a bribe is...more

Doing Business in Cuba Under the FCPA – Part II

Today, I continue my exploration of doing business in Cuba from the Foreign Corrupt Practices Act (FCPA) perspective. Yesterday, I made clear that anyone you do business with in Cuba is going to be a foreign official under...more

Key Findings from NAVEX Global's Third Party Risk Management Benchmark Report

Vendor risk management and, in particular, third party risk management has become one of the toughest issues companies face—especially after a string of high-profile compliance failures in recent years. The majority of...more

Will the FCPA Go Down Under (again)?

We do not often have the chance to go ‘down under’ at the FCPA Compliance and Ethics Blog. However, there is a case brewing that may have some Foreign Corrupt Practices Act (FCPA) implications as well as Australian...more

A Lesson in Compliance: Part II

The following is an interview with Richard Bistrong and Alessia Lamonaca, Program Marketing Specialist at Resolver Inc. In “A Lesson in Compliance with Richard Bistrong: Part I“, Richard discussed the thought process...more

A Lesson in Compliance: Part I

You’ve been quite candid with your followers and readers about your compliance violations and subsequent jail term. One of your blog posts addressed the stark reality you experienced when you first found yourself sitting in a...more

Massachusetts-Based Technology Company and Two Chinese Subsidiaries Pay $28 Million to Settle Civil and Criminal FCPA Charges; SEC...

On February 16, the SEC and DOJ announced a settlement with a Massachusetts-based technology company for violations of the FCPA. The technology company and two Chinese subsidiaries agreed to pay $28 million to settle the...more

Amsterdam-Based Telecommunications Company Pays $795 Million to Settle FCPA Charges Both in US and Abroad

On February 18, an Amsterdam-based telecommunications company and its Uzbek subsidiary reached a global settlement with the SEC, DOJ, and Dutch regulators Openbarr Ministerie (OM) and the Fiscal Intelligence and Investigation...more

The Season of Giving in Asia

Happy New Year of the Monkey! February 8th was the beginning of the two-week long celebration of the Spring Festival, or the Lunar New Year, in China and other countries in Asia. While this season of greetings and...more

VimpelCom Final Thoughts

Today, I conclude my exploration of the VimpelCom Foreign Corrupt Practices Act (FCPA) enforcement action. As I said yesterday, this case will be studied for some time as a textbook example of bribery schemes used...more

VimpelCom Settles FCPA Case – Part III

Today, I continue my exploration of the lessons to be learned from the VimpelCom Ltd. (VimpelCom) Foreign Corrupt Practices Act (FCPA) enforcement action. While it is clear that the company and its Uzbeki subsidiary, Unitel...more

PTC Settlement: Compliance Reminders for Internal Controls, Travel and Gifts

PTC, a Massachusetts software company, reached settlements with the SEC and DOJ last week for FCPA violations for a total of $28 million. Interestingly, the SEC announced a DPA with a PTC official who assisted in the...more

VimpelCom Settles FCPA Case – Part II

Today, I continue my exploration of the resolution documents from the long-standing Foreign Corrupt Practices Act (FCPA) probe into the Dutch telecom giant VimpelCom Ltd. (VimpelCom) for a spectacular, long-standing bribery...more

The Force Awakens: Vimpelcom’s FCPA Settlement and the Wreckage Left Behind (Part II of II)

The Vimpelcom FCPA enforcement action is stunning in its breadth and the brazen nature of the bribery scheme. It is hard to accept that such conduct stretched into 2011 to 2013, given the significant emphasis placed on...more

Is There an Internal Ethics & Compliance Council In Us All?

The following guest post and video is by Nicole Rose, CEO and Founder, Create Training. We all know about ‘the law’, but how about the laws within us that direct our behavior and decisions? Marc Hauser, evolutionary...more

Return of the Jedi (DOJ): The Vimpelcom Enforcement Action (Part I of II)

Welcome back to the Department of Justice and FCPA enforcement. After a lengthy hiatus, DOJ returned to the FCPA enforcement scene with a demonstration of its full capability, assuming certain individuals are prosecuted...more

More FCPA Grief Involving Gifts, Travel & Entertainment: PTC in China – Part I

Sometimes you have to wonder just how long it will take before US companies realize (1) there is a Foreign Corrupt Practices Act (FCPA) and (2) it applies in China as yesterday both the Department of Justice (DOJ) and...more

France’s Foreign Public Corruption Law (Article 435-3)

The chart traces the flow and logic of Article 435-3 (proscribing foreign corruption), discusses the Government’s 2015 anti-corruption “Compliance Guidelines,” and summarizes the pending anti-corruption...more

First DPA in the U.K. Signals Britain is Serious About Bribery & Corruption

Late last year, ICBC Standard Bank Plc, a U.K.-based financial institution with operations around the world, agreed to pay a $37 million fine and enter into a deferred prosecution agreement (DPA) with British financial...more

Digging Into Your Internal Controls

Corruption risks follow the money. If a company has effective controls over money, then the company has a good chance of mitigating corruption risks. A key indicator of a company’s internal controls is to ask if the...more

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