Compliance Dept. of Justice 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 -
News & Analysis as of

How Did This End Up On My Desk? | Anti-Bribery Compliance Panel Recap

“How did this end up on my desk?” Richard Bistrong, former front-line international businessman, contemplated at a panel last Thursday, how a letter had reached him from the Procurement Task Force of the United Nations...more

What Would Dr. Seuss Say about an Allowance?

Earlier this month we had the release of a second book by Harper Lee, “Go Set a Watchman”, which was miraculously discovered having been written some 50+ years ago. This week, there was another release from a (now deceased)...more

Private Equity’s Corruption Risk Underbelly — Portfolio Companies

FCPA enforcement will likely take a turn into the private equity industry. I know this is a regular claim by FCPA practitioners but we already can see the beginning of the trend. The “princeling” investigations are...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

Louis Berger International Pays $17 Million Penalty for FCPA Violation

On July 17, 2015, Louis Berger International, Inc., a New Jersey-based construction management company, entered into a deferred prosecution agreement (DPA) with the Department of Justice under which it agreed to pay a $17.1...more

Great Structures Week V – The Tacoma Narrow Bridge Failure and Preventing Failure in Your Compliance Program

I conclude my Great Structures Week with a focus on structural engineering failures: suspension bridges and the challenges of wind in their construction and maintenance. I am drawing these posts from The Great Courses...more

Great Structures Week II – Structures from Ancient Egypt and Greece

I continue my Great Structures Week with a focus on great structures from the earliest times, ancient Egypt and Greece. I am drawing these posts from The Teaching Company course, entitled “Understanding the World’s Greatest...more

Top Ten International Anti-Corruption Developments for June 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

June FCPA Compliance Digest | BONUS: Global Anti-Corruption and Anti-Money Laundering News

I love writing articles where I get to discuss companies making history. PetroTiger has been exonerated from criminal FCPA prosecution by the DOJ. That’s only happened once before, in the case of Morgan Stanley....more

How Companies Could Avoid “Paper” Compliance in New Ukraine? Try Acting Rather Than Talking

Ed. Note-today we have a guest post from two noted compliance practitioners from Ukraine, Timur Khasanov-Batirov and Andriy Selepey who discuss the dangers of a paper compliance program. Corruption is the main problem...more

Corporate Investigations & White Collar Defense - June 2015

The Unfolding FIFA Scandal: Will the DOJ Show the Banks a Red Card? - Why it matters: The worldwide soccer community has for years decried the brazen corruption that permeated FIFA, international soccer’s governing...more

Firm Settles FCPA Claim With Non-Prosecution Agreement, VP Pleads Guilty

IAP Worldwide Services Inc., a Virginia based facilities management firm, entered into a non-prosecution agreement with the Department of Justice and agreed to pay a $7.1 million penalty to resolve FCPA charges. A vice...more

George Carlin and Erga Omnes: the Petrobras Bribery Scandal Expands

On this date in 2008 George Carlin died. If you grew up in the late 1960s or early 1970s and you had anti-parental or anti-establishment inklings, which of course all teenagers do, you knew about George Carlin. In the early...more

The War of 1812 and the IAP Worldwide Services Non-Prosecution Agreement

On this day, 203 years ago, President James Madison signed a Declaration of War against Great Britain inaugurating the War of 1812. The cause of the war was multi-faceted; the formal reason given was the British impressment...more

The Costs and Risks of Corruption: Impacts beyond the Bribe

Anti-corruption news often revolves around the costly criminal and civil enforcement penalties paid by companies caught in corruption scandals. In the U.S., those costs often reach the hundreds of millions of dollars and are...more

Never Tick Off a Redbird

At a Press Conference today, Satan officially announced that Hell has frozen over. He made this stunning announcement after the New York Times (NYT) reported that the baseball team with the most World Series wins in the...more

Like a Rolling Stone and Charitable Donations Under the FCPA

Today we celebrate one of the seminal achievements in rock and roll for it was on this day, 50 years ago, in 1965 that Bob Dylan recorded his single Like a Rolling Stone. Columbia Records executives initially rejected the...more

FIFA and BHP Billiton: The Unique FCPA Challenges Present in International Sports

Recent enforcement actions by the Department of Justice and Securities and Exchange Commission have raised the profile of corruption in international sport and highlight unique FCPA compliance concerns. This note will explain...more

May FCPA Compliance Digest | Interactive, Engaging FCPA Training from the Start

You’ve been reading the FCPA Compliance Digest for five months now, and there’s still not a shortage of companies getting into trouble for violating the FCPA. That may seem like an obvious statement, but running out of news...more

Two Sides of A Global Corruption Investigation at Anti-Corruption Oslo

This is the second part of my interview with Robert (“Bob”) Appleton, which is timely given our question and answer session at the upcoming Anti-Corruption Conference, Oslo, where we will engage in an interview titled...more

FIFA, the DOJ and the Global Fight Against Corruption

The Department of Justice (DOJ) gave the global fight against anti-corruption a huge boost last week when it announced it was bringing charges against 14 members or persons associated with Fédération Internationale de...more

The FIFA Indictments and Travel Act Prosecutions under the FCPA

While the indictments last week against 14 individuals who were members or associated with Fédération Internationale de Football Association (FIFA) did not include any alleged violations of the Foreign Corrupt Practices Act...more

Global Anti-Corruption Enforcement Trends Hit FIFA

Insights on the anti-corruption trends that contributed to the Fédération Internationale de Football Association (FIFA) scandal, and six essential characteristics of organizations whose cultures help prevent bribery and...more

Economic Downturn Week, Part II – The Golden Gate Bridge and Employment Separation – Hotlines and Whistleblowers During Layoffs

I use the Golden Gate Bridge as an entrée to my continued discussion on the series on steps that you can use in your compliance program if you find yourself, your company or your industry in an economic downturn. Whether you...more

Preventing the Worst: Stopping Obvious and Bold FCPA Violations by Executives

Last year, a number of corruption cases, both individual prosecutions and suits against companies, revolved around the behavior of senior executives. While third parties can often be the vehicle companies use to funnel bribe...more

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