Compliance Dept. of Justice The Foreign Corrupt Practices Act

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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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

Breaking Down Compliance: The Keys to Creating a Successful Compliance Program—As Told through the Letters of COMPLIANCE

Still being a young role and profession, many people are working to define what makes a successful compliance professional and program, and what can help them improve. After traveling the country for the past few months at...more

3 Ways to Improve Compliance Training

As the compliance profession matures and evolves, the elements of an effective compliance program follow a similar pattern. Compliance training programs have become more sophisticated over the last five years, as...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 III – The Roman Arch and Resourcing Your Compliance Program

I continue my Great Structures Week with focus on structural engineering innovations from ancient Rome. I am drawing these posts from The Teaching Company course, entitled “Understanding the World’s Greatest Structures:...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

Great Structures Week I: Vitruvius, the Brooklyn Bridge and Compliance

I recently completed a course from The Teaching Company, entitled “Understanding the World’s Greatest Structures: Science and Innovation from Antiquity to Modernity”, taught by Professor Stephen Ressler. It was a wonderful...more

Private Equity FCPA Enforcement

FCPA enforcement efforts are not so hard to follow and predict – the government likes to provide advance warnings as an effective means of deterrence. Justice Department and SEC officials will often tell the public their...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

The Third Man and the Authority of Chief Compliance Officers

Harry Lime is back, although he really never left us. As reported by Kristin M. Jones in a Wall Street Journal (WSJ) article, entitled “Harry Lime Reborn”, the glorious British film noir The Third Man, written by Gra ham...more

June Whistleblower Digest | Does Your Ethics Training Adequately Cover Anti-Retaliation?

Pop quiz: what are the three criteria the SEC stated they would hold a chief compliance officer accountable for? Well, I admit that was a trick question, because even if you got them right, the SEC is ruffling feathers by...more

The Sioux at Little Bighorn and Using Risk Going Forward

I recently wrote about the stupidity of General Custer and the defeat of his Calvary at Little Bighorn as a lead in for the failure to adequately assess and then manage risks in a Foreign Corrupt Practices Act (FCPA)...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

What the Government Expects to Find in an Anti-Corruption Compliance Program

Similar to Foreign Corrupt Practices Act enforcement generally, the federal government has expanded what it expects to find in an anti-corruption compliance program. U.S.-connected companies operating internationally...more

DOJ Breaks its Silence in 2015 FCPA Enforcement

Last week, the DOJ announced its first corporate enforcement action under the Foreign Corrupt Practice Act (“FCPA”) for 2015. IAP World Services, Inc., a Florida-based defense and government contractor, agreed to pay $7.1...more

Government Contracting Abroad: Beware Compliance Risks

On June 16, 2015, IAP Worldwide Services Inc., a private defense and government contracting company, agreed to pay $7.1 million to settle criminal charges of the U.S. Foreign Corrupt Practices Act (FCPA) related to bribing...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

FCPA Compliance and Ethics Report-Episode 171-FCPA Enforcement in the Energy Industry [Video]

In this episode I discuss enforcement of the FCPA in the energy industry, it genesis and the business response by the energy industry. ...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

Tribute to John David Crow and an Innovation Strategy for Your Compliance Program

John David Crow died Wednesday. Until Johnny Football, he was the only football player from Texas A&M University to win the Heisman Trophy. He played under the legendary Paul ‘Bear’ Bryant at A&M and for all of Bryant’s...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

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