Corruption

News & Analysis as of

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

They Grow Up So Fast: Alstom and the UK Bribery Act at Five Years

In April 2015, the UK Bribery Act (UKBA) celebrated its fifth birthday. In the same month, the Serious Fraud Office brought a third round of corruption charges under the UKBA in the Alstom case. Those allegations, brought...more

The Thrill is Gone: On the Intersection of CSR and the FCPA

Somehow it seems fitting that the legacy of BB King inform today’s blog post which is about the intersection of Corporate Social Responsibility (CSR) and anti-corruption laws such as the US Foreign Corrupt Practices Act...more

I Was An Irrational Compliance Calculator

In what might be described as a “companion guide” to my Ethikos article Does Compliance Need More “Darkside,” I had a chance to read Scott Killingsworth’s work in the same edition, The Irrational Calculator: Sales at the...more

Lunch with the FCPA Compliance and Ethics Blog – Donald Anderson of TDI

I recently had the chance to sit down for a lovely lunch at the Federal Grille with Donald Anderson, the Partner in Charge for TD International’s (TDI) Houston Office. Donald is a Louisiana native who attended LSU, receiving...more

Summary Judgment Overturned In Coverage Dispute

In late April, the Indiana Supreme Court held that Continental Casualty Company (“CNA”) must provide insurable relief for Anthem Insurance Companies, Inc. (“Anthem”), reversing a lower court decision. Anthem’s expenditures...more

China Regulatory Enforcement Quarterly - Q1 – 2015 |

Inside This Issue: - Executive Summary - PRC Legal and Regulatory Updates - Major Enforcement News - China Communist Party Titles 101 - AIC Penalties Increase Risk of Dual Enforcement Actions - Frequently Asked...more

Definition of corrupt conduct: The High Court has limited the scope of the New South Wales Independent Commission Against...

A majority of the full court of the High Court of Australia has upheld the decision of the New South Wales Court of Appeal that the Independent Commission Against Corruption (ICAC) has no power to conduct an inquiry into...more

Compliance: It Starts With A Village

A few weeks ago I had Mike Kenealy, COO of Insiders Integrity engage in a Q and A on “Just ‘Say No’ to Bribery but Prepare First. A Front Line Story,”. Last week, Mike shared with me a pro-bono project that he had sA few...more

The Easter Rebellion and Petrobras’ $17 Billion Write Down

On this day, 99 years ago the Easter Rebellion began. If there is one event that is seared into history as a turning point for Irish independence from Britain, it was the Easter Rebellion. England had finally granted Home...more

Brazil Bribery Scandal Reaches Advertising Agencies

Humans are good at avoidance and can even reach a state of blatant disregard. The corruption news coming out of Brazil is so far-reaching that it is almost numbing....more

The Intersection of the FCPA, TI-CPI and Tax Appeals in Brazil

The Transparency International-Corruptions Perceptions Index (TI-CPI) is released each year in November. The TI-CPI rates Brazil as 69th out of 175 countries on its index, coming in with a score of 43 out of 100. I wonder if...more

Beyond the Foreign Corrupt Practices Act (FCPA)

When Ethical Boardroom invited me to write this article, I started thinking about issues that go beyond the ‘bolt-on’ model of anti-bribery compliance. For, as Alison Taylor, director of energy and extractives at BSR...more

Government suppliers face tighter anti-corruption, IP compliance in EU

As the European national governments implement the new EU Public Procurement Directive, government suppliers face tighter restrictions on bribery and other corruption activities and potentially even IP infringements going...more

Taking the Rolls Out for a Spin? Maybe You Should Avoid Brazil

Just as the GlaxoSmithKline PLC (GSK) case in China heralded a new day in international anti-corruption enforcement, the Petrobras case may be equally important going forward. The scope and breadth of the investigation is...more

Foreign Bribery And Corruption - Australian Law

Increasingly, Australian companies are entering into cross border business relationships and in doing so are discovering that the law and the local culture can be quite different. This is especially true in the use of bribes...more

Goodyear Settles SEC FCPA Charges

Goodyear Tire and Rubber Company settled FCPA books and records and internal control charges with the SEC. The settlement reflects the extensive cooperation and remedial efforts of the company. In the Matter of Goodyear Tire...more

Goodyear’s Settlement with the SEC Emphasizes the Importance of FCPA Due Diligence in M&A Transactions and of Having a Robust...

On February 24, 2015, Goodyear Tire & Rubber Co. agreed to pay more than $16 million to settle charges that two of its subsidiaries allegedly paid $3.2 million in bribes that generated $14,122,535 in illicit profits. The SEC...more

Culture Corrupts: The Impact of Organizational Silence

Today I welcome Organizational Psychologist Jamie-Lee Campbell to a Q & A. Please note that the interview with Jamie is quite extensive, so today I am posting a consolidated portion of our discussion, with some minor edits....more

Canada Lays Corruption and Fraud Charges Against SNC-Lavalin

On February 19, 2015, the RCMP laid corruption and fraud charges against the SNC-Lavalin Group Inc., its division SNC-Lavalin Construction Inc., and its subsidiary SNC-Lavalin International Inc. under section 3(1)(b) of the...more

Anticorruption Compliance: From Our Founding Fathers to the Present

The Foreign Corrupt Practices Act of 1977 (FCPA) prohibits making—or even offering to make—any corrupt payment to foreign officials to further business interests. However, concerns about corruption stem back to the times of...more

Jail for UK directors and corporate sentencing to come

The prosecution of Smith and Ouzman Ltd. for bribery is winding to a close, with the sentencing of two directors of the company for corruption....more

Bone-headed Moves on the Football Field and Idiotic Statements About Corruption

That football truism (allegedly) came from former Texas Longhorn head coach Darrell Royal. While he intoned it in a different era, Pete Carroll and his Seattle Seahawks proved it still to be valid in the most recent Super...more

A Most Violent Year – Doing What is Most Right

It is rare to say but Hollywood occasionally can provide us with ethics and compliance lessons. My wife and I recently saw the movie, A Most Violent Year. It is worth seeing – not just for entertainment, but also for the...more

Corruption in America

The focus on the FCPA provides a myopic view of corruption. Bribery of foreign officials is only one slice of the corruption pie. Even though the United States ranks number 19 in Transparency International’s Corruption...more

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