News & Analysis as of

Corruption

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

UK Criminal Finances Act 2017: A Dechert "Dirty Money" Trilogy

by Dechert LLP on

Part One: "A Fistful of Tax Dollars" - A New Corporate Offence of Failure to Prevent the Facilitation of Tax Evasion.. The Criminal Finances Act 2017 represents a further significant development in the approach to the...more

This Week in FCPA-Episode 54, the Rubber Match Edition [Video]

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. Tom reports on Compliance Week 2017? 2. If the DOJ releases new information in the form of the...more

Transparency in FCPA Enforcement

by Michael Volkov on

We all value transparency as a general concept, especially when it comes to the government. In a real macro perspective, we fund the government and we demand that our government operate efficiently, effectively and ethically....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

Understanding Special Counsel Mueller’s Authorization

by Michael Volkov on

Deputy Attorney General Rosenstein’s appointment of Special Counsel Robert Mueller last week was a blockbuster development in the investigation of the administration....more

Does Your Organization Need an Anti-Bribery Management System?

Microsoft and Wal-Mart recently announced that their organizations recognize the value of having a uniform international standard across their organizations to combat bribery, and will now be seeking ISO 37001 Certification...more

Obstruction of Justice – A Primer

by Michael Volkov on

Our political discourse these days has been focused on three key words – obstruction of justice. Whatever your politics may be, these words and the law surrounding obstruction of justice are important to understand....more

English Court Questions the Application of Litigation Privilege in Criminal Investigations

On 8 May 2017, the English High Court of Justice handed down judgment in The Director of the Serious Fraud Office v. Eurasian Natural Resources Corporation Ltd,1 which could significantly limit the application of litigation...more

From Dr. No to an Agile Compliance Program

by Thomas Fox on

How agile is your compliance program? How does this fit into the operationalization requirement laid out in the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (Evaluation)? While many have argued...more

China State Secrets: What Multinational Companies Need to Know

by Kobre & Kim on

Multinational companies in China used to have the luxury of focusing their regulatory efforts primarily on compliance with the laws of their home countries, relegating China’s state secrets laws to something only of concern...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

The Compliance Profession and the Demand for “Results”

by Michael Volkov on

Compliance professionals are riding high. They are the darlings of the corporate governance world, commanding higher salaries, C-Suite positions with access to senior leadership and the board, and an empowered position within...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

The Danger of Corporate Scandals – When CEOs and Senior Executives Circle the Wagons to Impugn a CCO

by Michael Volkov on

We all know the scenario. A corporate scandal breaks, heads will roll and criminal investigators have invaded a company to investigate and prosecute the CEO, senior executives and others. It is a toxic environment when this...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

AG Jeff Sessions Left Compliance Officers with More Questions than Answers … and an Invitation

by NAVEX Global on

Attorney General Jeff Sessions was a keynote speaker at the 2017 Ethics & Compliance Initiative’s Annual Conference last week. Whatever your politics are, it was important that we hear from him on his priorities for...more

What is the Real Risk of an FCPA Enforcement Action?

by Michael Volkov on

When speaking to clients or potential clients, the question of risk of enforcement is the moose on the table. Sometimes, the question gets asked and other times, the subject is never discussed. To be fair, it is not an easy...more

“Zen and the Art of Motorcycle Maintenance” – Lessons for Compliance

by Thomas Fox on

Robert M. Pirsig died last week. For anyone who went to college in the mid-70s, he was required reading in a variety of classes and disciplines for his seminal work Zen and the Art of Motorcycle Maintenance. There were a...more

First 100 Days of the Trump Administration and The FCPA – Same As It Ever Was

by Thomas Fox on

Over the weekend, we had the first 100 days of the Trump administration. To commemorate this constructed time for review of any new administration I gathered the Everything Compliance podcast panel of Mike Volkov, Jay Rosen,...more

Frontier Markets – Smallest Markets Represent Promising but Overlooked Investment Opportunities

The general public may not be familiar with the term “frontier market,” but frontier markets represent the vast majority of the fastest-growing economies in the world. The term “frontier market” generally refers to the...more

AI for Risk Management in Compliance – A New Business Advantage

by Thomas Fox on

There have been some articles recently which discussed the revolution of technology into compliance, specifically with the introduction of Artificial Intelligence (AI) into the profession. A few pieces claimed this was...more

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