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Corruption Compliance

ISO 37001: Board, Top Management and Anti-Bribery Compliance Responsibilities (Part III of V)

by Michael Volkov on

In Part III of my continuing series on ISO 37001, today I examine the board and top management’s respective responsibilities in the implementation and oversight of an anti-bribery management system....more

ISO 37001: The Good, The Bad and the Ugly (Part II of V)

by Michael Volkov on

In Part II of my continuing series, I identify in broad strokes some of the more significant positive and negative aspects of ISO 37001. While it is easy to second-guess the ISO 37001 authors, there are some interesting...more

SCCE Compliance and Ethics Institute – Eugene Soltes and How Compliance Programs Works

by Thomas Fox on

The first full day of the SCCE 2017 Compliance and Ethics Institute (CEI) featured a talk by Eugene Soltes, an associate professor at Harvard Business School and author of “Why They Do It”. For this book Soltes spent over...more

For the Benefit of Mr. Kite – Fiction in the World of Quality Assurance

by Thomas Fox on

The basics were laid out by Peter Wells and Emiko Terazono in a Financial Times (FT) article entitled “Kobe Steel scandal hits Boeing, Toyota and Nissan”. The Japanese company admitted it had falsified “inspection data on an...more

Steering the course – navigating bribery and corruption risk in private equity investments: Part 3

by Hogan Lovells on

Identifying Bribery and Corruption risk in the context of private equity investments (and M&A more generally) is key to ensuring the value of an acquisition. Companies will busy themselves with due diligence on tax,...more

Steering the course – navigating bribery and corruption risk in private equity investments: Part 1

by Hogan Lovells on

Identifying Bribery and Corruption risk in the context of private equity investments (and M&A more generally) is key to ensuring the value of an acquisition. Companies will busy themselves with due diligence on tax,...more

It’s A Slam Dunk: Take Steps Now To Avoid Tough Lessons Learned By Several NCAA Basketball Programs

The recent indictment of at least 10 individuals associated with college basketball should alert every university, and many businesses, to the importance of operating strong ethics and compliance programs and conducting...more

What a CCO Can Learn from Da Vinci

by Thomas Fox on

When Walter Isaacson publishes a book, you would do well to read it. His previous books have included biographies of such disparate luminaries as Steve Jobs, Albert Einstein, Henry Kissinger and Benjamin Franklin. My personal...more

Where O’ Where Did Our Monitors Go? — The Telia Bribery Case

by Michael Volkov on

Just when everyone was anticipating the beginning of an uptick in FCPA enforcement in 2017, the Justice Department and the SEC delivered a resounding message to remind everyone that FCPA enforcement is here to stay. However,...more

The Fraud Triangle, Rationalizations and Compliance Programs

by Thomas Fox on

The fraud triangle is well-known to most compliance practitioners. Its third sides are pressure, opportunity and rationalization. When these three factors converge, there is danger of an ethical lapse which could lead to...more

Tribute To Gogos – New Corruption Scandal In College Sports

by Thomas Fox on

October is my annual Classic Monster Movie month tribute. I recognize it is not yet October but I wanted to begin a bit early this year as September saw the passing of Basil Gogos. He was the prime illustrator for the...more

Telia FCPA Enforcement Action: Part IV – Getting Some Monies Back

by Thomas Fox on

I have spent the past few blog posts reviewing the many lessons that can be garnered by the compliance practitioner from the Telia Company AB (Telia) Foreign Corrupt Practices Act (FCPA) resolution. However, there is one...more

The Telia FCPA Resolution: Part III – The Individuals

by Thomas Fox on

I continue my exploration of the Telia Company AB (Telia) Foreign Corrupt Practices Act (FCPA) enforcement action and the parallel actions. Today I will consider the individuals who have been criminally indicted in Sweden and...more

DOJ And SEC Bring Major FCPA Enforcement Actions Against Swedish Telecom Firm, Imposing One Of Largest FCPA Penalties In History

by Shearman & Sterling LLP on

On September 21, 2017, the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced significant enforcement actions against Telia Company AB, a Swedish telecommunications firm, for alleged...more

The Telia FCPA Resolution: Part II – The Bribery Schemes

by Thomas Fox on

Over the next few blog posts, I will be exploring the resolution and what lessons the compliance practitioner can draw from the Telia Company Foreign Corrupt Practices Act, (FCPA) enforcement action, the parallel actions and...more

Compliance Lessons From Burner Phones

by Thomas Fox on

Hunter S. Thompson once said that when the going gets weird, the weird turn pro. It turns out that amateurs can get weird too. The University of Mississippi football program, which is under a self-imposed postseason ban and...more

Book Review: The Chickenshit Club

by Thomas Fox on

To my mind the most significant and important book that every Chief Compliance Officer (CCO), General Counsel (GC) and compliance practitioner needs to read is The Chickenshit Club by Pulitzer Prize winning journalist Jesse...more

Dorsey Anti-Corruption Digest - September 2017

by Dorsey & Whitney LLP on

Keeping ahead of global anti-corruption trends is critical in today’s business markets. The Dorsey Anti-Corruption Digest, which puts global trends at your fingertips, puts you ahead. The deep experience of the Dorsey...more

The Objective of Due Diligence: To Protect Your Culture

by Michael Volkov on

There has been so much attention paid to due diligence. We have reams and reams of articles highlighting the importance of due diligence. In addition, numerous vendors of due diligence services and technologies fill the...more

Tales from the Corporate Scandal Crypt: GM, VimpelCom, VW and Wells Fargo

by Michael Volkov on

We are fascinated by corporate scandals. Since the 1980s, the US public has enjoyed unraveling corporate scandals, and vilifying corporate leaders caught in the web of deceit and misconduct. I am sure there are historical...more

Ethics and Compliance Training, What Gets Results?

The following interview is with Dr. Patricia Harned, Chief Executive Officer of the Ethics & Compliance Initiative (ECI). RB: Pat, it’s a pleasure to have you join us today, and thank you for sharing your report “Ethics...more

Midnight Cruising with Steely Dan – Finding Patterns in Raked Leaves

by Thomas Fox on

Last Friday on September 1, I began a new installment of my year-long podcast series, where each month I focus on a different compliance topic. This month, I am focusing on innovation in compliance....more

How the Storms of “The Scottish Play” Inform Your Compliance Program

by Thomas Fox on

In honor of fellow Houstonians, fellow Texans and now our neighbors to the east in Louisiana, who have been impacted by Hurricane Harvey, I continue my weather themed week by considering how Shakespeare used weather as a...more

Foreign Corrupt Practices Act 2017 Mid-Year Update

by BakerHostetler on

The first half of 2017 has been eagerly anticipated following the record-setting year in 2016 for Foreign Corrupt Practices Act (“FCPA”) enforcement by both the U.S. Department of Justice (“DOJ”) and the U.S. Securities and...more

Hurricane Harvey – Reflections on Being Prepared

by Thomas Fox on

We are now half way (hopefully) through what is predicted to be the largest amount of rain seen in one week by the city of Houston and its surrounding environs in the city’s recorded history. First and foremost, my deepest...more

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