Corruption Compliance

News & Analysis as of

Spain Sets a New Milestone with its Corporate Compliance Statute

As of July 1 of this year, Spain becomes the latest in a string of nations with a corporate compliance defense. Article 33 of Spain’s criminal code will provide an exemption from corporate criminal liability where the company...more

Farewell to Chocolate Thunder, Baylor Football and Due Diligence

Daryl Dawkins died yesterday. To anyone who followed the National Basketball League (NBA); Dawkins will always be remembered with the brilliant Stevie Wonder-derived moniker – Chocolate Thunder. I will also remember him for...more

Foreign Corrupt Practices Act (FCPA): Israel Beware – Trends in Enforcement

Intuitively, Israeli companies and their directors would likely assume that their businesses are immune to investigation and the assessment of penalties by US regulators that are separated by a vast ocean and located more...more

You Don’t Have to be a Hero Not to Pay a Bribe

Sometimes a hero can make a difference. But you do not have to be a John Wayne type-hero to make such a difference. The reason is the world is made up of real people and John Wayne heroes only exist in the movies. Even in the...more

Amazon’s Culture, the Greatest Brawl in Baseball and Compliance

One of the strangest incidents in the history of Major League Baseball (MLB) recently had its 50 anniversary. It involved a brawl between Hall Of Fame pitcher Juan Marichal and catcher John Roseboro. The game was between the...more

Best Practice Internal Controls For Reducing Fraud And Corruption Risk

Fraud and corruption risk are inevitable, yet every company should strive to reduce these risks. For Compliance Week, Jeffrey Harfenist (BDO Consulting, Global Forensics), Stephanie Giammarco (BDO Consulting, Forensic...more

Give & Take: The Case for a Better G&E Compliance Program

Part One: Setting The Foundation - Why Does G&E Matter? Tony Robbins once said, “Every problem is a gift—without problems we would not grow.” In the compliance arena, the reverse also applies, as many gifts can...more

Archie Bunker, Batgirl and the International Fight Against Corruption

This week saw the death of two notables from the television industry, Bud Yorkin and Yvonne Craig. According to his Obituary in the New York Times (NYT), Yorkin rose up the television industry ranks to eventually team with...more

Anti Bribery Compliance Training and Policies For Global Companies: Localize or Standardize?

One of the top priorities for compliance professionals today is training their global workforces on anti corruption and anti bribery, particularly in those areas of the world in which these practices represent cultural norms....more

New Citywide Construction Fraud Task Force Promises Tough Enforcement

On August 5th, the Manhattan District Attorney (the "DA’s Office") announced the formation of a multi-agency Citywide Construction Fraud Task Force that will be spearheaded by prosecutors from the office. Its mission is...more

July FCPA Compliance Digest | Bonus: Global Anti-Corruption News

July was a quiet month for FCPA compliance news. There were some rumors that the SEC and DOJ were in the process of revising A Resource Guide to the US Foreign Corrupt Practices Act, but unfortunately The FCPA Blog shut down...more

The BHP Case and Enforcement of The FCPA’s Internal Controls Provision

Ed. Note-today we have a guest post from Jean-Michel Ferat ,CPA, CFF is a Managing Director in the Washington D.C office of the Claro Group around his views on the BHP Billiton enforcement action. Much has been made in...more

PetroChina Class Action Dismissed

On August 3, a federal district court in New York dismissed with prejudice a securities class action suit filed against Chinese oil and gas company PetroChina Co. Ltd. The suit alleged that statements in the company’s 2011...more

A Summer of Compliance

When I was working in the field of international sales, August was typically a month of ‘down time’ as a combination of end user, third party and corporate holidays marked a lull in summer sales activity. Well, I have not...more

Corrective Actions: When Corruption Happens on Your Watch

As news stories, case studies, academic literature and enforcement actions illustrate, a company can have a robust anti-corruption program in place, yet can face investigations and possible liability for the corrupt actions...more

What Goes Downhill May Go Uphill in FCPA Compliance

Usually the question I am posed is how far down the chain must you go in your due diligence to ensure that your suppliers are in compliance with the Foreign Corrupt Practices Act (FCPA). I would pose that now, after the...more

[Webinar] Why and How to Manage Gift and Entertainment Disclosures - August 26, 1:00 EDT

Gifts and entertainment go hand in hand with bribery and anti-corruption. That’s why compliance teams need to take a proactive approach to managing this common risk—relying on financial teams and records to track G&E won’t...more

5 Signs Your Anti-Corruption Compliance Program is Suffering from “Tunnel Vision”

Many companies, depending on the industry, have implemented anti-corruption compliance programs. Some of the programs meet the standard for an “effective” anti-corruption compliance program. There is a vast difference between...more

DOJ Hires Compliance Counsel to Assist in Charging Decisions

New Compliance Counsel Will Assess Effectiveness of Corporate Compliance Programs - Last week the U.S. Department of Justice (DOJ) revealed it is hiring a compliance counsel to assist DOJ prosecutors in assessing the...more

Mead Johnson: Baby Formula and Bribes

Last week, the SEC announced a settlement of an FCPA enforcement action for $12 million against Mead Johnson Nutrition for payment of bribes in China to health care professionals at state-owned hospitals. Mead Johnson’s...more

What Compliance Teams Need to Know About G&E Management: Breaking it Down to Help You Proactively Manage Gifts and Entertainment

Gift and entertainment (G&E) costs are a natural part of doing business. But like all good things in life, there is a fine line that shouldn’t be crossed. Giving a prospect a weeklong vacation to a tropical island may be an...more

FinCrimes Update - July 2015 Summary Volume 2, Issue 7

AML/BSA & OFAC: OFAC PROVIDES GUIDANCE TO FINANCIAL INSTITUTIONS TO HELP COMPLY WITH CRIMEA SANCTIONS REGULATIONS - On July 30, OFAC issued a “Crimea Sanctions Advisory,” highlighting certain actions that have been...more

Social Media Week Part II – Sharing in the Compliance Function

I continue my exploration of the use of social media as a tool of doing compliance by looking at some concepts around the sharing of information. In a recent podcast on Social Media Examiner, entitled “Sharing: The Art and...more

Social Media Week Part I – Using Social Media In Your Compliance Program

Welcome to Part I of Social Media Week. I recently did a webinar, hosted by The Network, on the use of social media in your Foreign Corrupt Practices Act (FCPA) compliance program. The response was as great as almost any...more

Does Trade Facilitation Matter in the Fight against Corruption?

Today’s guest post comes from Evelyn Suarez, Principal, The Suarez Firm. The World Trade Organization’s (WTO) Trade Facilitation Agreement (TFA) may seem to be an odd topic for an anti-corruption blog but it is not. It...more

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