Chief Compliance Officers The Foreign Corrupt Practices Act

News & Analysis as of

[Event] Why Anti-Bribery Programs Fail and How Compliance Must Evolve - Sept. 17th, Boston, MA

In a “Catch Me If You Can” like panel, a former US and UN prosecutor and former FCPA violator/ turned cooperator discuss the realities of corporate anti-bribery compliance. It’s not often that compliance officers are...more

Give & Take: The Case for a Better G&E Compliance Program

Part One: Setting The Foundation - Why Does G&E Matter? Tony Robbins once said, “Every problem is a gift—without problems we would not grow.” In the compliance arena, the reverse also applies, as many gifts can...more

BNY Mellon and Lessons Learned In Hiring Family Members – Part II

In yesterday’s post I reviewed the Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action involving the Bank of New York Mellon Corporation (BNY Mellon) around its hiring of sons and...more

BNY Mellon Settles First Sons and Daughters (and Nephews) FCPA Hiring Matter – Part I

Yesterday the Securities and Exchange Commission (SEC) announced a resolution with Bank of New York Mellon Corporation (BNY Mellon) for violations of the Foreign Corrupt Practices Act (FCPA). This was the first enforcement...more

Georgia On My Mind – How Does Compliance Enhance Shareholder Value?

Can you get a sense of place from listening to a song? In an article in the Financial Times (FT), entitled “The Life of a Song – Georgia On My Mind”, Mike Hobart wrote that when you “combine Stuart Gorrell’s lyrics with Hoagy...more

The BHP Case and Enforcement of The FCPA’s Internal Controls Provision

Ed. Note-today we have a guest post from Jean-Michel Ferat ,CPA, CFF is a Managing Director in the Washington D.C office of the Claro Group around his views on the BHP Billiton enforcement action. Much has been made in...more

Latin America Corruption: Keep Calm, Carry On?

Recently, governmental authorities have pursued corruption investigations in Latin America with a vigor traditionally not seen. One potential result is a significant disruption of business. While there are inherent risks in...more

A Summer of Compliance

When I was working in the field of international sales, August was typically a month of ‘down time’ as a combination of end user, third party and corporate holidays marked a lull in summer sales activity. Well, I have not...more

What Goes Downhill May Go Uphill in FCPA Compliance

Usually the question I am posed is how far down the chain must you go in your due diligence to ensure that your suppliers are in compliance with the Foreign Corrupt Practices Act (FCPA). I would pose that now, after the...more

Social Media Week Part VI – Social Media and CCO 3.0

I conclude this exploration of the uses of social media in doing compliance by exploring why the compliance function is uniquely suited to using social media tools. Long gone are the days when Chief Compliance Officers (CCO)...more

5 Signs Your Anti-Corruption Compliance Program is Suffering from “Tunnel Vision”

Many companies, depending on the industry, have implemented anti-corruption compliance programs. Some of the programs meet the standard for an “effective” anti-corruption compliance program. There is a vast difference between...more

DOJ Hires Compliance Counsel to Assist in Charging Decisions

New Compliance Counsel Will Assess Effectiveness of Corporate Compliance Programs - Last week the U.S. Department of Justice (DOJ) revealed it is hiring a compliance counsel to assist DOJ prosecutors in assessing the...more

Social Media Week Part V – Tools and Apps for the Compliance Practitioner

To conclude this week’s posts, I wanted to list some of the more prevalent social media tools, explain what they are and how you might use them in a compliance program. (As usual I got carried away so this series will...more

Social Media Week Part III – Twitter and Innovation in Your Compliance Program

I continue my exploration of the use of social media in your Foreign Corrupt Practices Act (FCPA) compliance program today. One of the ways that Chief Compliance Officers (CCOs) and compliance practitioners can communicate...more

Social Media Week Part II – Sharing in the Compliance Function

I continue my exploration of the use of social media as a tool of doing compliance by looking at some concepts around the sharing of information. In a recent podcast on Social Media Examiner, entitled “Sharing: The Art and...more

Social Media Week Part I – Using Social Media In Your Compliance Program

Welcome to Part I of Social Media Week. I recently did a webinar, hosted by The Network, on the use of social media in your Foreign Corrupt Practices Act (FCPA) compliance program. The response was as great as almost any...more

How to Succeed In Compliance – The Compliance Retreat

In 1961, one of my favorite Broadway musical comedies appeared How to Succeed in Business Without Really Trying. It ran for over 1400 performances in its original Broadway run and was based on the 1952 book by Shepherd Mead,...more

One Anti-Corruption Compliance Panel: Multiple Perspectives

On July 23rd, 2015 at the Hotel Kitano in New York City, The Network (www.tnwinc.com) hosted an Anti-Corruption Compliance Panel discussion titled “Why Anti-Bribery Programs Fail and How Compliance Must Evolve.” Cindy Curtin...more

The Kitchen Debate Presages the FCPA Compliance and Ethics Report

On this day in 1959, occurred one of the more iconic events of the Cold War, that being the Kitchen Debate between US Vice President Richard Nixon and Soviet leader Nikita Khrushchev. It was called ‘The Kitchen Debate’...more

Selecting Compliance Counsel

I have often wondered who is FCPA Inc. and perhaps even how I might join this seemingly august fraternity if they do allegedly make so much money, as some commentators regularly deride FCPA Inc. for the seemingly outlandish...more

Breaking Down Compliance: The Keys to Creating a Successful Compliance Program—As Told through the Letters of COMPLIANCE

Still being a young role and profession, many people are working to define what makes a successful compliance professional and program, and what can help them improve. After traveling the country for the past few months at...more

Farewell to Moe Green and the Promise to Pay a Bribe Under the FCPA

Moe Green died again yesterday but this time he was not shot through the glasses, it was from cancer and the fictional Las Vegas mobster lived to the ripe old age of 79. Of course I am referring to “Alex Rocco, the veteran...more

Lack of Bribery Act Awareness by One-Third of UK Small Businesses Poses Risk for Partners

A U.K.-government-commissioned survey of 500 businesses known as “small and medium sized enterprises” (SMEs) in the United Kingdom released in July 2015 found that more than one-third of the businesses had never heard of the...more

DOJ–Louis Berger, Two Executives Resolve FCPA Charges

The DOJ resolved another FCPA action with the company entering into a deferred prosecution agreement, paying a criminal fine and agreeing to the imposition of a monitor after self reporting and cooperating. Two of the firm’s...more

Great Structures Week IV – The Gothic Cathedral and Compliance Incentives

I continue my Great Structures Week with focus on great structural engineering and its innovations in the medieval world – that being the Gothic Cathedral. I am drawing these posts from The Great Courses offering, entitled...more

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