News & Analysis as of

Corruption

Retaining a “Risky” Third-Party

by Michael Volkov on

Every company has done it. Chief Compliance Officers have had to hold their respective noses and push forward with due diligence to retain a risky third party. Rather than reject the third party, a CCO convinces him or...more

Frontier Markets Require a Long-Term Investment in Compliance & Success

by NAVEX Global on

The rewards from investing in so-called “frontier markets” are enticing: rapid growth with unexploited niches, often marked by youthful consumers excited with their new found discretionary cash. These are the regions that...more

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS - U.K. Opens Corruption Investigation of Rio Tinto over Guinea Operations - On July 24, 2017, the United Kingdom’s Serious Fraud Office (SFO) announced that it had opened an investigation...more

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS - U.K. Opens Corruption Investigation of Rio Tinto over Guinea Operations - On July 24, 2017, the United Kingdom’s Serious Fraud Office (SFO) announced that it had opened an investigation...more

'Unmasking' Corruption

The following is an interview with Anne-Christine Wegener, co-author, “Unmasked: Corruption in the West.” RB: Dear Anne-Christine, first, thank you for taking the time to meet with me during my recent trip to Heidelberg,...more

High-Profile Spanish Money Laundering Investigation of Chinese Bank Raises Questions About Future of Similar U.S. Enforcement

by Ballard Spahr LLP on

As widely reported, the Spanish police raided last year the Madrid offices of the Chinese state-run Industrial and Commercial Bank of China (“ICBC”), the world’s biggest bank by assets. In the nearly 18 months following that...more

Dorsey Anti-Corruption Digest - August 2017

by Dorsey & Whitney LLP on

The Department of Justice (DOJ) ended its probe of Net1 UEPS Technologies, according to SEC filings from the South African-based payment processing company. The company received a declination from the Securities and Exchange...more

Red Notice Newsletter - July 2017

ANTICORRUPTION DEVELOPMENTS - U.K. Opens Corruption Investigation of Rio Tinto over Guinea Operations - On July 24, 2017, the United Kingdom’s Serious Fraud Office (SFO) announced that it had opened an investigation...more

How Do You Define a Compliance Program Failure?

by Michael Volkov on

In our perpetual quest for simplicity, sometimes we fail to understand the complexity of an issue. In the corporate world, if you ask board members and CEOs how they would define a compliance program ”failure,” I am sure...more

The Perfect Compliance Combo: Culture and Controls

by Michael Volkov on

Compliance practitioners divide their commentary and insights into two general categories – ethical culture and compliance controls. It is easy to divide compliance issues into these two categories. Ethical culture articles...more

Lessons in Failures of Internal Controls

by Thomas Fox on

Last week’s announcement by the Securities and Exchange Commission (SEC) of the resolution of its outstanding Foreign Corrupt Practices Act (FCPA) enforcement action with Halliburton Company continues to resonate and provide...more

Goodbye to Rocket J. Squirrel – Halliburton Resolves FCPA Enforcement Action

by Thomas Fox on

June Foray died this week. You may not think you have heard of her but let me assure you; you have heard her. Foray was the voice of Rocket J. Squirrel in perhaps the greatest cartoon show ever, Rocky and Bullwinkle....more

Compliance and the Noble Fight Against Corruption

by Thomas Fox on

In two recent public appearances, Department of Justice (DOJ) representatives spoke to issues of concern to every compliance practitioner regarding one role of the DOJ going forward and how that role will continue to feed the...more

DOJ Issues Two Declinations in First Corporate FCPA Enforcement Actions of the Trump Administration

by Allen & Overy LLP on

Speed read - In June 2017, the U.S. Department of Justice (DOJ) issued two “Declinations with Disgorgement” under the DOJ’s Pilot Program. The declinations were received by U.S. subsidiaries of the Linde Group (Linde) and...more

White Collar Watch (July 2017 • Vol 1, Issue 2)

by Blank Rome LLP on

Welcome to the summer edition of Blank Rome’s White Collar Watch. In a world that seems to bring new challenges daily—such as the global cybersecurity attacks that were launched in late June—this newsletter is designed to...more

FCPA under the New Administration

by Blank Rome LLP on

The single most frequently asked question by our international clients over the past several months is whether there will be changes in white collar prosecution priorities under the new administration, specifically with...more

Should You Record Internal Investigation Interviews?

by Michael Volkov on

As a former federal prosecutor, I noticed a renewed discussion of the important question of whether witness interviews should be recorded (either audio or video). I have always found this issue to be interesting and have...more

Alleged Nigerian Oil Industry Corruption and Civil Forfeiture: More Extraterritorial Application of U.S. Law; More High-End Real...

by Ballard Spahr LLP on

On Friday, the Department of Justice (“DOJ”) filed a civil forfeiture complaint in the Southern District of Texas seeking recovery of approximately $144 million in assets that allegedly represent the proceeds of foreign...more

New Revenue Recognition Standard – Part VI: What Does Mean?

by Thomas Fox on

Over several blog posts, I have explored in detail the new Financial Accounting Standards Board (FASB) Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), which set forth a new Revenue...more

2nd Circuit Weighs in on Certifying Classes Involving Foreign Securities

by Burr & Forman on

In In re Petrobras Securities Litigation, the Second Circuit Court of Appeals recently issued an opinion regarding the standards for certifying a class involving foreign securities. Petrobras is a multinational Brazilian gas...more

The Second Circuit Overturns Watershed Conviction Of Sheldon Silvery Based On Recent Supreme Court Decision

by Shearman & Sterling LLP on

On July 13, 2017, the U.S. Court of Appeals for the Second Circuit overturned the high-profile, political corruption conviction of one of the most powerful politicians in New York State— former Speaker of the New York State...more

New Revenue Recognition Standard – Part V: Allocation and Revenue Recognition

by Thomas Fox on

I continue to explore the Financial Accounting Standards Board (FASB) issued Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), for public business entities, certain not-for-profit...more

New Revenue Recognition Standard – Part IV: Determining the Transaction Price

by Thomas Fox on

This week I am exploring the Financial Accounting Standards Board (FASB) issued Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), for public business entities, certain not-for-profit...more

Ontario Court Upholds Landmark Anti-Bribery Conviction

On July 6, 2017, in R. v. Karigar, the Ontario Court of Appeal (Court) dismissed an appeal by Mr. Nazir Karigar of his conviction for agreeing to offer a bribe to a foreign public official, contrary to section 3(1)(b) of the...more

European White Collar Crime Report: Views on the key developments across Europe

by Allen & Overy LLP on

Europe at a glance - Across Europe, law makers are steadily expanding the circumstances in which companies can be found liable (whether criminally or otherwise) for the criminal conduct of their employees and other...more

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