News & Analysis as of

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

Bribery and Conflicting Messages

“Take risks” and “Don’t expose the company to bad press.” So begins a Harvard Business Review article “When Your Boss Gives You Conflicting Messages,” and “Prevent Conflicting Messages from Confusing Your Team,” by Len...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

“Is the Current Compliance Model Working?”

An interview with Richard Bistrong. You must read it. Find out about bribery from the front line from someone who has been there, seen it, done it and got the jumpsuit. Originally published on...more

Leading Pharmaceutical Company Fined $491 Million for Bribery

A Chinese court convicted a large British pharmaceutical company of corruption and bribery while doing business in China. As a result, the company must pay a record-breaking fine of $491 million while each of the implicated...more

“Corruption: Misunderstanding the Impact.”

As I have shared in prior blogs, from the vantage point of business class and inner city hotels, there is an unhealthy distance and an often ethical unawareness from front lines of international business, when it comes to the...more

Anti-Bribery Training from Coca-Cola: What I Learned About Bribery, Corruption and Responsibly Entering Underdeveloped Markets

A few weeks ago, I had the pleasure of attending the 22nd Annual Ethics and Compliance Conference, hosted by the ECOA. I’m always intrigued by how the topics of a conference tie together; for example, one of the speakers on...more

8 Tips for Verifying the Effectiveness of Corporate Anti-Corruption Programs

In the past 20 years, considerable progress has been made in developing corporate anti-corruption programs, as companies recognize the damaging effects of bribery and corruption on business, reputations and the global...more

Third Parties and Red Flags

The following is our second Q & A with Richard Bistrong. In your view why do sales representatives or front line business personnel engage in bribery or hire a third party for the express purpose of paying a...more

Top 10 tips for countering small bribes

The issue of so-called facilitation payments and other small bribes is a thorn in the side of many international businesses. Not only is it difficult to do business in many parts of the world without making such payments, but...more

Bribery at the “Sharp End.” Lessons from the field.

To many, an understanding of corruption, bribery and compliance comes from the field of regulators, auditors, investigators and attorneys. Each one of these practices brings an important perspective and set of compliance...more

Internal Controls for Third Party Representatives in a FCPA Compliance Program

This week, I am continuing my podcast series, on the FCPA Compliance and Ethics Report, on internal controls in best practices anti-corruption compliance program, under the Foreign Corrupt Practices (FCPA), UK Bribery Act or...more

The Origins of the FCPA: Lessons for Effective Compliance and Enforcement: Part Two

The illicit or foreign payments cases - The preliminary inquiry was followed by formal SEC investigations early in 1974. The resulting cases would become known as the “illicit or foreign payments” cases. The focus of...more

Fraud and Bribery – They Go Hand in Hand

Compliance officers need to dig into and understand a company’s internal controls. Many compliance officers tend to leave that issue to Internal Auditors – that is a big mistake....more

Risk Assessments-the Cornerstone of Your Compliance Program, Part I

One cannot really say enough about risk assessments in the context of anti-corruption programs. Since at least 1999, in the Metcalf & Eddy enforcement action, the US Department of Justice (DOJ) has said that risk assessments...more

5 CEO’s Who Should Be Forced To Retake Anti Bribery Training

5 CEO’s Who SIn my last blog I wrote about billionaire Bernie Ecclestone bribing his way out of a bribery sentence; I’m still shaking my head on that one. Sadly, he is not the only mega rich businessman behaving badly,...more

3 Depressing Conclusions in E&Y’s Global Fraud Report – More Anti-Bribery Training, Internal Controls Required

I just finished reading Ernst & Young’s “Growing Beyond: A Place For Integrity”, the company’s 12th Global Fraud Survey. It’s pretty sobering, but I’m trying to find some glimmers of hope in it. Don’t get me wrong; the...more

Bribery, Twice Removed

Charles Duross is the head of Morrison & Foerster’s Global Anti-Corruption Practice. He is the former head of the Department of Justice’s Foreign Corrupt Practices Act unit, where he took a leading role in developing and...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

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

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 FIFA Flop: Why Anti-Bribery Training is More Important Than Just Knowing How To Play The Game

Brazil passed their new anti-bribery law back in January. Only a couple of months before the 2014 World Cup was set to start, Brazil, the host country of the famous “football” world championship, offered guidance about their...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

In Due Diligence and World Cup Bids: Follow the Money

For those watching the 2104 World Cup, this year’s tournament has certainly been spectacular, from the US reaching the round of 16, the incredible goals scored by Robbie Van Persie and Tim Cahill, to yesterday’s heartbreak...more

Coolness in Being the Bad Guy? Eli Wallach and GSK

Eli Wallach died Tuesday. For my money, he was about the coolest bad guy out there. Not tough like Lee Marvin, just cool. My favorite Wallach roles were as Calvera in The Magnificent Seven and as Tuco in The Good, The Bad and...more

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