Compliance Anti-Corruption

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
News & Analysis as of

Predicting the Future: What Would Truly Global Anti-Corruption Enforcement Look Like?

Within the SEC and DOJ’s blockbuster ending to 2016 was the Odebrecht settlement. The amount involved, a stunning $4.5 billion (pending a possible reduction for inability to pay), grabbed headlines around the world. But...more

Trends from 2016 Record FCPA Enforcement Year (Part II of III)

No matter how you cut it – this was a big year in FCPA enforcement. Not just because of the large enforcement actions but the scope and depth of enforcement, remediation and compliance program demands....more

Badda Bing, Badda Boom!! — DOJ and SEC Make 2016 a Record Year for FCPA Enforcement (Part I of III)

We begin the New Year with a three-part series on the FCPA: (1) A review of FCPA enforcement in 2016; (2) Trends from 2016 FCPA enforcement; and (3) Predictions for FCPA enforcement in 2017....more

A Merry (Compliance) Christmas and Tribute to Jim McGrath

Ed. Note-Jim McGrath was a great friend and a trusted colleague who passed away in 2014. As a tribute to McGrath and for Christmas this year, I submit for your enjoyment, the below post which originally appeared on McGrath’s...more

Focus On Enabling Your People, Not Controlling Them, To Create an Effective Compliance Culture

When employees of all levels believe in and support policies and standards, that’s when you see real compliance. In-house perspective from NetApp GC, Matt Fawcett....more

"New French Anti-Corruption Legal Framework"

A new French law titled “Transparency, the Fight Against Corruption and Modernization of the Economy,” which was published in the French Official Journal on December 10, 2016 (known as Sapin II, as it was named after the...more

Top Ten International Anti-Corruption Developments for November 2016

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Institutional Justice and Compliance

I end my week based upon recent obituaries by focusing on one from late 2015 that has been the most significant to me in the year of 2016. It was that of my father, Dr. Milden Jean Fox, Jr., who passed away on this date one...more

Combatting corruption risk in the Asia Pacific region: What next?

The election of Donald Trump as the next US president has raised fundamental questions about the role of the United States going forward, and what implications this will have globally. This presents renewed challenges for...more

France’s Major Anti-Corruption Reform: What’s Next for Companies and Their Top Management?

Changes to France's anti-bribery system require large companies and their top management to implement an anti-corruption compliance program. After a new examination of the bill by both Chambers of Parliament and the...more

Dave Edwards, the Doomsday Defense and Execution in Compliance

Baker Hughes Inc. Chief Compliance Officer (CCO), Jay Martin, often says that execution is where the rubber meets the road in compliance. I thought about all of that in the context of some of the pronouncements the Department...more

New Compliance Regulations for France and Italy Demonstrate the Growing Convergence of Anti-Corruption and Whistleblowing...

A piece of major compliance legislation has just been passed in Europe: the long-awaited French anti-corruption and whistleblower protection law, Sapin II, which brings French anti-corruption standards in line with those of...more

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

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

Third-Party Risk Programs Should Focus on Offense, not Defense

Just 43 percent of organizations surveyed in NAVEX Global’s 2016 Ethics & Compliance Third Party Risk Management Report said they evaluated third parties before engaging with them—down from 68 percent in 2015....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

Top Ten International Anti-Corruption Developments for October 2016

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Recent Developments in Japanese Enforcement of Foreign Bribery Laws

In recent years, Japan has been under increasing scrutiny and pressure from the international community regarding its enforcement of its anti-corruption laws. A signatory to the OECD Anti-Bribery Convention, Japan enacted an...more

ISO 37001: Answers to the 5 Questions We’ve Heard Most About the Standard

It’s been a month since ISO 37001 was published and there are some questions we have heard percolating in the compliance world about what this means. These are the questions we’ve been hearing the most...more

Compliance Isn’t Going Away (and neither should you) – Part II

I am writing a series on why compliance is not going away under a Trump administration and why you should not either. Today, I want to focus on the most bottom line of all business reasons, that being that compliance is good...more

Compliance Isn’t Going Away (and neither should you) – Part I

Yesterday I presented my views on why I believe that Foreign Corrupt Practices Act (FCPA) enforcement will continue under the new administration. Today, I want to begin a multi-part series (sorry I don’t know how long it will...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

Corporate Corruption, Culture and Compliance (Part II) [Video]

In part II of my interview on CCTV America, The Heat (October 25th), I respond to questions about the hazards which can occur when compliance leaders lose their “line of sight” into the business. I also share my...more

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