News & Analysis as of

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

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

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

Q & A with Sarah Chayes: Author, “Thieves of State.” The ‘Odorless Gas’ of Corruption.

Today is part II of my interview with Sarah Chayes, Author, Thieves of State, Why Corruption: Threatens Global Security. This week I am particularly excited about my post, as on Tuesday, February 10th, I will have the...more

January FCPA Enforcement Digest – FCPA Compliance Training Top Priority in 2015

With as much FCPA activity as we saw in December, I thought our January news digest might take on a different flavor. I was wrong – January brought a slew of new FCPA-related stories. ...more

New Year, New Focus on Enforcement: The U.K. Strengthens Anti-Bribery and Corruption Enforcement

U.K. regulators have started 2015 with a bang, promising increased cooperation among regulatory agencies, and tougher enforcement of financial crimes, with an emphasis on anti-bribery and corruption efforts....more

"United States: International Cooperation, Anti-Corruption and Tax Remain Key Issues for Enforcement Authorities"

U.S. authorities continue to aggressively pursue cross-border investigations and to scrutinize closely the compliance programs of multinational corporations. Investigative activity by U.S. authorities in 2014 was particularly...more

2014 Corruption Perceptions Index Highlights Need for Greater International Cooperation

Following the release of Transparency International’s 2014 Corruption Perceptions Index (CPI), the international watchdog group urges greater international cooperation to stem corruption and abuses of power that undermine...more

OECD Foreign Bribery Report: Leveraging The How, Where And Why Of Bribery To Bolster Your Ethics And Compliance Training Program

In my last blog post, “The OECD Foreign Bribery Report: 7 Insights To Improve Your Ethics And Compliance Training Program,” I identified the seven bribery trends covered in OECD’s Foreign Bribery Report. The report listed...more

The OECD Foreign Bribery Report: 7 Insights to Improve Your Ethics And Compliance Training Program

According to Ernst and Young’s ‘Navigating today’s complex business risks Europe, Middle East, India and Africa Fraud Survey 2013,’ half of workers surveyed across Europe, the Middle East, Africa and India believe bribery and...more

Top Ten International Anti-Corruption Developments for November 2014

For busy in-house counsel and compliance professionals, we have tried to summarize the most important international anti-corruption developments in the past month with links to primary resources. November was definitely a...more

International Anti-Corruption Day

Today is International Anti-Corruption Day. This occasion is a good opportunity to think about whether your organization has sufficient systems, policies and controls in place to ensure ethical and responsible business...more

Knowing When to Fold — Arguing the FCPA’s Definition of “Foreign Official”

With lots of fanfare, Esquenazi and Rodriguez, and the usual suspects filed a cert petition and briefs in support of the appeal from the 11th Circuit Court of Appeals’ decision affirming the lower court’s interpretation of...more

Leading Pharmaceutical Company Fined $491 Million for Bribery

A Chinese court convicted a large British pharmaceutical company of corruption and bribery while doing business in China. As a result, the company must pay a record-breaking fine of $491 million while each of the implicated...more

Hammer Films’ Frankenstein and the Monster of Corruption in Brazil

Today we celebrate the initial two Hammer Films Frankenstein entries into the horror pantheon. These classic films, from the 1950s, were the The Curse of Frankenstein and The Revenge of Frankenstein. In both films Peter...more

Corruption and Compliance In Russia: A Long Term View

The following is an interview conducted via e-mail with Anatoly Yakorev, Director at the Center for Business Ethics & Compliance, Moscow, Russia. ...more

FinCrimes Update - September 2014 Summary, Volume 1, Issue 7

IN THIS ISSUE: BSA/AML & OFAC | Virtual Currency & Payment Systems | FCPA & Anti-Corruption | Criminal Enforcement. BSA/AML & OFAC: FINCEN OFFERS RED FLAGS GUIDANCE ON HUMAN TRAFFICKING AND...more

8 Tips for Verifying the Effectiveness of Corporate Anti-Corruption Programs

In the past 20 years, considerable progress has been made in developing corporate anti-corruption programs, as companies recognize the damaging effects of bribery and corruption on business, reputations and the global...more

GSK China: Did Case Finish with a Bang or a Whimper?

In typical Chinese fashion, the prosecution of GSK and several GSK executives ended after a one-day “trial.” GSK paid a $489 million fine; and four criminal sentences were handed out with suspension of jail time and orders of...more

China Amps Up Anti-Corruption Effort – What This Means for Your Company

Last Friday, China’s 15-month-long bribery investigation into British multinational pharmaceutical GlaksoSmithKline (GSK) ended after a one-day trial in which the court found GSK’s local subsidiary guilty of bribing doctors...more

Corruption Prevention in South Africa

As part of my outreach to bring in the perspective of others who confront corruption on the front lines of international business, I decided to start a series of interviews from those who have expertise in their home...more

GSK Convicted – We are really, really sorry we paid bribes (and got caught)

“GSK plc sincerely apologies to the Chinese patients, doctors and hospitals, and the Chinese Government and the Chinese people.” With those words, the British pharmaceutical giant GlaxoSmithKline (GSK) PLC was...more

Bribery at the “Sharp End.” Lessons from the field.

To many, an understanding of corruption, bribery and compliance comes from the field of regulators, auditors, investigators and attorneys. Each one of these practices brings an important perspective and set of compliance...more

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