Compliance Bribery

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 -
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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

12 Tips for an Effective Due Diligence Program for Third Parties

In an evolving global economy, expanding business opportunities often lead to more complex supply channels and business relationships that can increase corruption risks and burden efforts to comply with the applicable laws...more

FCPA Compliance and Ethics Report-Episode 65-World Cup Report-Part I [Video]

The FCPA Compliance and Ethics Report, Episode 65 is out. In this episode, I begin a 4 part World Cup series with Mike Brown, Managing Director of Infortal. In this episode we discuss bribery and corruption of referees and...more

Anti-Corruption Digest

Anti-Corruption Digest is an update distributed on a monthly basis by Dorsey & Whitney providing a summary of the latest developments in anti-corruption enforcement activity around the world. In This Issue: -...more

May Flowers for GSK? The Corruption Investigation Deepens

April showers bring May flowers, at least that is the old truism. One place it is decidedly correct is at the RHS Chelsea Flower Show, which began its run as one of the, if not the greatest, annual flower shows in the world...more

Cisco and Russia — Perils of Corruption in Russia

Cisco’s 2009 audits concerning its operations in Russia revealed that its interactions with the state-owned company, Svyazinvest and local resellers, could not be “verified.” An interesting phraseology to say the least,...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

Warning all Foreign Companies in China: Don’t be the next GlaxoSmithKline

The fact that GlaxoSmithKline (GSK) has been on China’s radar for bribery is nothing new – the Chinese authorities instituted an investigation against the company in July 2013. What is new is that GSK’s former Vice President...more

Mitigating Bribery Risks With Financial Controls

Anti-corruption compliance is not as hard as it looks. In fact, by taking a step back, compliance professionals can gain insights. At the direction of compliance professionals, companies like to develop and adopt...more

Just Say No: Refusing To Pay Bribes

I was never a big fan of the Reagan Administration’ solution to America’s drug problem – Just Say No. The phrase was a simple solution to a more complex problem, one that people now recognize as a health problem rather than...more

The General Motors Scandal: Risky Issues

The GM scandal is unfolding and provides important reminders for everyone involved in compliance and how to respond to a corporate scandal....more

Deemed Public Officials: A Potential Risk for US Companies in Japan

Japan is one of the lower-risk countries for US companies in terms of compliance issues involving bribery and corruption. Transparency International’s 2013 Corruption Perceptions Index places Japan 18th out of 177...more

Weekly Recap Ethics News and Trends – March 3, 2014

Public servants with the utmost integrity also need to be aware of what is happening ethically around the state. In today’s climate, every public agency’s image is impacted by the missteps or misconduct of others. Below...more

Bribery Is Bribery

FCPA practitioners, commentators and yes, even the FCPA Paparazzi, all spend a lot of time discussing, analyzing and posing theoretical questions related to the legal issue of who is a “foreign official” under the FCPA. The...more

Where O’ Where Is The Board Of Directors?

If you trace the path of an FCPA violation inside an organization, at a minimum, you will see a path of lost opportunities, oversights and omissions. If you see anything different, you may be looking at a deliberate scheme...more

China Compliance Update: Commercial Bribery Risks Remain Very Real in China

The enactment of new legislation, as well as new and continuing investigations, demonstrates that Chinese regulators have not slowed down their efforts to ferret out corruption in the pharmaceutical sector and related...more

The European Commission Unveils its First EU Anti-Corruption Report, Highlighting the Continuing Risk of Corruption in EU Member...

On February 3, 2014, the European Commission published its first Anti-Corruption Report (the “Report”). The Report covers all types of corruption, including political corruption, bribery of public officials, and private or...more

Shirley Temple And Excellence In FCPA Training Video

Today we honor one of the most interesting personalities of the 20th century, Shirley Temple, who died yesterday. She was probably the greatest child actress of all-time, being the lead grossing star for five straight years...more

The Simon-Sting Tour And New Information In Your Compliance Program

This past weekend I saw the first show in a multi-city tour by Sting and Paul Simon. I have never been a big Sting or Police fan but I am a huge Paul Simon fan, in all his musical incarnations. As it was their first show,...more

Crude Allegations: Corruption in the Energy Trading Sector

The world-wide energy trading sector, where traders match physical supply and demand of energy by purchasing, reselling, and moving commodities (crude oil and refined products, natural gas, coal, and even electricity) across...more

Political Law Briefing - February 2014

In this issue: - Note: You Can Still Tune-Up on Government Affairs Compliance - FPPC Goes After More Committees in Its "Dark Money" Case - Down But Not Out: IRS Cites Political Activity in Denying Groups...more

Executives: The Organization’s Gifts Policy Also Applies to You

Last week the Department of Justice formally charged ex-Virginia Governor Bob McDonnell and his wife with illegally soliciting and accepting lavish gifts and entertainment as well as loans from the (now former) CEO of Star...more

Weekly Recap Ethics News and Trends – February 3, 2014

Public servants with the utmost integrity also need to be aware of what is happening ethically around the state. In today’s climate, every public agency’s image is impacted by the missteps or misconduct of others. Below...more

The Engineer’s Thumb And How To Bribe

We conclude our week of Sherlock Holmes inspired themes with one of the few cases in which Holmes fails to bring the criminals to justice, The Adventure of the Engineer’s Thumb. Once again using the Holmes tale as a...more

The So-Called Re-Emergence Of Gifts, Meals And Entertainment As A Compliance Problem

Forgive me for taking the FCPA Paparazzi to task but when they deserve it, they deserve it. A quick diversion — I often am asked by fellow bar members and commenters if I am referring to them as being a member of the...more

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