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

Reflections on the Hitachi FCPA Enforcement Action

Earlier this week, the Securities and Exchange Commission (SEC) announced resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Hitachi Ltd (Hitachi). There were several interesting aspects to...more

Health Update - September 2015

Latest Healthcare False Claims Act Roundup and Top 3 Best Practices to Reduce Exposure - As the legal landscape in healthcare becomes increasingly complex, healthcare companies that receive federal program funds face...more

The Defeat Device: Compliance and Ethics in the Auto Industry

Things are seriously bad when one of the world’s most respected business focused publications, the Financial Times (FT), asks if the auto “industry faces ‘Libor moment’”? Yet that was a headline yesterday in the lead article...more

Cleaning Up a Compliance Program Mess

You have just been hired as the new Chief Compliance Officer of a global company operating in over 80 countries, including numerous high-risk corruption countries. You have no staff and have been given a budget to hire 5...more

New DOJ Compliance Counsel: Doing Compliance Now Even More Critical

Last Friday, the FCPA Professor reported: “According to this Global Investigations Review article: “According to two people familiar with the matter, the US Department of Justice (DoJ) has hired Hui Chen, Standard...more

Bribery and Behaviors from the Front-Lines

Tell me a little bit about your background and how you came to be an anti-bribery consultant. My entry point into the defense business was as a fourth generation family member of what at the time (the mid 80's) was one...more

Corruption Risks in Brazil: Ensuring Compliance with the FCPA & BCCA

Brazil is one of the hardest places in the world to do business – the World Bank Doing Business Report 2014 ranked Brazil 116 out of 183 for overall “ease of doing business.” In this on-demand webinar, Matteson Ellis of...more

Top Ten International Anti-Corruption Developments for August 2015

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 in the past month, with links to primary...more

Cartoons, Crime and Compliance

The full animation of “Why We Say Yes,” is now available by clicking on the above image. As a companion guide, here is my interview with Nicole Rose ([email protected]), creative founder, and CEO of Create Training and The...more

How Canada’s leading the way to compliance with anti-corruption sticks and carrots

“Your criminal actions raise serious questions as to whether you have the requisite personal integrity and business ethics to be a responsible Government contractor.” That’s me. I was debarred from being a U.S....more

Can Anti-Bribery Compliance Be Animated?

Caricatures can be found as far back as the 14th Century with Leonardo da Vinci. Martin Luther extensively used drawings of a more editorial nature in the Reform movement, and by the 18th century, animation had become a...more

The Case For A Better Gifts & Entertainment Compliance Program - Part One: Setting the Foundation

As explored in last month’s blog “What Compliance Teams Need To Know About G&E Management“, being able to proactively manage gifts and entertainment is crucial to a successful compliance program. Today, we’ll take the concept...more

Anti-Corruption Enforcement in Brazil is in High Gear

Headlines of Brazil’s push to fight corruption are everywhere. The Petrobras scandal involves contracts worth billions of dollars, and prosecutors have uncovered a U.S. connection. The public is outraged and has called for...more

The High Cost of an FCPA Violation

Violations of the Foreign Corrupt Practices Act (“FCPA”) can lead to hefty penalties. Indeed, individuals who violate the FCPA, and their employers, could be on the hook for a variety of penalties described below. Companies...more

The Case for a Better Gifts & Entertainment Compliance Program - Part Two: An Effective G&E Program

Previously we covered setting the foundation for a better G&E compliance program. In the second piece of The Case for a Better Gifts & Entertainment Compliance Program, we’ll look at the key components to having an effective...more

Spain Sets a New Milestone with its Corporate Compliance Statute

As of July 1 of this year, Spain becomes the latest in a string of nations with a corporate compliance defense. Article 33 of Spain’s criminal code will provide an exemption from corporate criminal liability where the company...more

Farewell to Chocolate Thunder, Baylor Football and Due Diligence

Daryl Dawkins died yesterday. To anyone who followed the National Basketball League (NBA); Dawkins will always be remembered with the brilliant Stevie Wonder-derived moniker – Chocolate Thunder. I will also remember him for...more

Foreign Corrupt Practices Act (FCPA): Israel Beware – Trends in Enforcement.

Intuitively, Israeli companies and their directors would likely assume that their businesses are immune to investigation and the assessment of penalties by US regulators that are separated by a vast ocean and located more...more

You Don’t Have to be a Hero Not to Pay a Bribe

Sometimes a hero can make a difference. But you do not have to be a John Wayne type-hero to make such a difference. The reason is the world is made up of real people and John Wayne heroes only exist in the movies. Even in the...more

Amazon’s Culture, the Greatest Brawl in Baseball and Compliance

One of the strangest incidents in the history of Major League Baseball (MLB) recently had its 50 anniversary. It involved a brawl between Hall Of Fame pitcher Juan Marichal and catcher John Roseboro. The game was between the...more

Best Practice Internal Controls For Reducing Fraud And Corruption Risk

Fraud and corruption risk are inevitable, yet every company should strive to reduce these risks. For Compliance Week, Jeffrey Harfenist (BDO Consulting, Global Forensics), Stephanie Giammarco (BDO Consulting, Forensic...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

Archie Bunker, Batgirl and the International Fight Against Corruption

This week saw the death of two notables from the television industry, Bud Yorkin and Yvonne Craig. According to his Obituary in the New York Times (NYT), Yorkin rose up the television industry ranks to eventually team with...more

Anti Bribery Compliance Training and Policies For Global Companies: Localize or Standardize?

One of the top priorities for compliance professionals today is training their global workforces on anti corruption and anti bribery, particularly in those areas of the world in which these practices represent cultural norms....more

July FCPA Compliance Digest | Bonus: Global Anti-Corruption News

July was a quiet month for FCPA compliance news. There were some rumors that the SEC and DOJ were in the process of revising A Resource Guide to the US Foreign Corrupt Practices Act, but unfortunately The FCPA Blog shut down...more

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