News & Analysis as of

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

Building a Next-Generation Anti-Bribery & Corruption Compliance Program

Global companies face unprecedented third party risk in today’s landscape — third parties are involved in 90% of Foreign Corrupt Practices Act (FCPA) cases, and more companies are under investigation than ever before in the...more

Naval Theorists And The Measurement Of Compliance

If are interested in naval history, strategy and tactics, I have a question for you: Are you a disciple of Alfred Mahan or Julian Corbett? If you are a Mahanian, you probably focus on large naval engagements or the great...more

Individual FCPA Enforcement Actions In 2013

This year had the largest number of individual Foreign Corrupt Practices Act (FCPA) enforcement actions since 2010, the year of the Gun Sting case. Here are the highlights of FCPA related enforcement actions against...more

FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions [Video]

In this episode, I review the corporate FCPA enforcement actions of 2013. ...more

Ignoring The Obvious: Facilitation Payments

Chief Compliance Officers have plenty of issues to focus on when it comes to anti-corruption compliance. If you rank the risks, facilitation payments are not at the top of the list, especially if you have sales staff and...more

China And Compliance Solutions: Choking Off The Money Supply

Compliance is hard enough even when the issues are simplified, the tasks are defined, and the strategies are straightforward....more

Mr. Bourke Heads To Jail – If Only He Had A Compliance Officer At The Table

After years of litigation and twists and turns, Mr. Bourke finally entered jail to serve his one year and one day sentence. ...more

The Danger Of FCPA “Proactive” Investigations

The old adage – if something is too good to be true, it probably is not – applies with equal force in the world of bribery and intrigue. The recent arrest of the mining executive for obstruction of the Justice Department’s...more

Suzanne Rich Folsom and Bart M. Schwartz on Corporate Compliance in 2011  [Video]

As part of a continuing series of LEVICK video interviews with thought leaders across multiple disciplines and industry sectors, I recently sat down with Suzanne Rich Folsom, the former Vice President, Chief Regulatory and...more

Glengarry Glen Ross and the Internal Marketing of a Compliance Program

One of the great plays and movies that I enjoy is ‘Glengarry Glen Ross’. As you might expect with anything that David Mamet pens the dialogue is absolutely spot on, fast paced and non-stop. The action generally revolves...more

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