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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 -

FCPA Compliance Challenges & New Lines of Defense

In part one of a two part interview, Joe Spinelli, Senior Managing Director, Kroll, addresses the recent Kroll-Ethisphere Anti-Bribery and Corruption Benchmarking Report. In this interview Joe focuses on: *The need and...more

Has the FCPA changed the US business culture?

by Thomas Fox on

In the early 70’s the Lockheed corruption scandals came into light. Millions of dollars had been paid by the US aircraft corporation to public officials to guarantee contracts for military aircraft in Germany, Italy, Japan,...more

The Government Uses Multiple Tools to Fight Corruption

by Thomas Fox on

There are multiple ways to deal with an issue which can provide known and unforeseen benefits. Today we celebrate one of those as it was on this day in 1944, that President Franklin Roosevelt signed the GI Bill into...more

Linde in the Republic of Georgia: A Declination and Lessons Learned

by Thomas Fox on

Yesterday the FCPA Professor reported the Department of Justice (DOJ) had issued a Declination to Linde North American Inc. and Linde Gas North America LLC (collectively “Linde”). This is the first Declination issued by the...more

Update on Regulatory Compliance in the Global Health Care Industry

by Baker Ober Health Law on

A comprehensive understanding of the constantly evolving layers that make up federal anti-corruption statutes, sanctions regulations and export control restrictions is imperative for both the pharmaceutical and health care...more

China Compliance, From Someone Who Knows

In today’s compliance environment, though we see a robust debate on what the new US administration might mean for anti-bribery compliance, the new ISO standard, and the recent DOJ “Evaluation of Corporate Compliance Programs”...more

Does Obeying the FCPA Hurt Your Recruiting?

by Thomas Fox on

Imagine your company has gone through a Foreign Corrupt Practices Act (FCPA) investigation. As you near the end of the investigative phase and move into the enforcement phase, you tell the government that you have terminated...more

The Challenge of Auditing and Monitoring Your Distributors

by Michael Volkov on

Whether you are in the high-tech industry and managing your channel partners (i.e. third-party distribution network), the pharmaceutical and medical device industry managing a complex network of distributors and...more

Farewell to Batman and Bringing Passion to Compliance

by Thomas Fox on

Adam West died this weekend. He was the TV Batman I knew growing up. They say the actor who first introduced you to a character will always be your favorite and while I am not sure if that holds true or not with West’s...more

Arbitration Bribery Corruption and Disputes - it's not as easy as ABCD

by Hogan Lovells on

Foreign Corrupt Practices Act ("FCPA") - For energy, mining, and resources companies, the cost of corruption—and getting caught—is real. Less than two months ago, Odebrecht S.A. was ordered by a U.S. federal judge to pay a...more

"Creating A Risk" Of Bribery Can Violate The FCPA: Low Threshold For SEC Enforcement Actions

by Allen & Overy LLP on

SEC enforcement actions under the U.S. Foreign Corrupt Practices Act have been setting an ever-lower threshold for violations of the FCPA's books and records, and internal controls provisions. Most recently, the SEC has...more

2016 - A Year for the FCPA Record Books & What It Means for Compliance Practitioners

by Thomas Fox on

We have never seen and may well never see again a year of Foreign Corrupt Practices Act corporate enforcements as we did in 2016. ...more

Why Compliance Must Manage Risk

by Thomas Fox on

What is risk to your company? In the anti-corruption world, it is conduct which might violate the Foreign Corrupt Practices Act (FCPA), UK Bribery Act, Brazilian Clean Companies Act or one of the other internationally focused...more

Day 3 of One Month to Better Investigations and Reporting-the Investigation Protocol

by Thomas Fox on

Your company should have a detailed written procedure for handling any complaint or allegation of bribery or corruption, regardless of the means through which it is communicated. The mechanism could include the internal...more

This Week in FCPA-Episode 55, the Covfefe Edition

by Thomas Fox on

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Brazilian meatpacker JBS agrees to the largest fine ever for fine for bribery and corruption, $3.2bn...more

Top Ten International Anti-Corruption Developments for April 2017

by Morrison & Foerster LLP on

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

Operationalizing Compliance: Part V – Controller’s Office

by Thomas Fox on

This week I have engaged in a series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I have been...more

From Bottom Bunk to Top Mind

I recently had the honor of being named to Compliance Week’s list of Top Minds for 2017, earning the title of “The Great Communicator” from Bill Coffin, Donna Rice, and the CW team....more

This Week in FCPA-Episode 53, the I left my heart in San Francisco edition

by Thomas Fox on

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Brazilian President Temer comes under corruption fire? 2. The turmoil at FIFA continues as FIFA’s...more

The Foreign Corrupt Practices Act and the New Trump Administration: Your Top Ten Questions Answered

by Foley & Lardner LLP on

Since mid-2000s investigation of Siemens, and the resulting $800 million penalty for violations of the Foreign Corrupt Practices Act (FCPA), the FCPA has been an enforcement priority of the U.S. Government. Although a dip in...more

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS – Former Magyar Telekom Executives Settle Bribery Charges – On April 24, 2017, the Securities and Exchange Commission (SEC) announced that two former executives of Magyar Telekom, a...more

Red Notice Newsletter - Chinese

Anticorruption Developments - Former Magyar Telekom Executives Reconcile Bribery Charges - April 24, 2017, the US Securities and Exchange Commission (SEC) announced that the Hungarian telecommunications company...more

Why Healthcare and Life Sciences Companies Need to Step Up Their Compliance Efforts in Advance of a U.S. Government Investigation

by Hogan Lovells on

In this hoganlovells.com interview, Hogan Lovells partner Gejaa Gobena discusses how the perception of compliance, remediation, and self-disclosure has evolved in the eyes of government prosecutors from how they factor at...more

Can One Really Track the FCPA?

The following Q & A is with Harry Cassin, CEO, Recathlon LLC, the parent company of the FCPA Blog. RB: Hi Harry, first, a little about you. How did you get to the FCPA world? HC: My father is the founder and...more

Wait a Minute – The FCPA Enforcement Sky Did Not Fall?

by Michael Volkov on

No matter what, I am an optimist. A pessimist’s worldview and lifestyle is really unattractive. I would always rather see the glass as half full. Too many in the professional world have confused negative perspectives and...more

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