Corruption Compliance

News & Analysis as of

Is the DOJ’s New FCPA Pilot Program an Offer You Can’t Refuse?

Earlier this month, Assistant US Attorney Leslie Caldwell announced that the US Department of Justice’s Criminal Division Fraud Section will try to entice companies to self-report potential FCPA issues. The DOJ included...more

Organizational Cultures of Corruption

The following guest post is by Alison Taylor. My new issue brief, published by the Columbia Law School Center for the Advancement of Public Integrity, is based on extensive academic research, a review of primary data...more

New DOJ Guidance and FCPA Pilot Program – Part III: Ongoing Remediation

I continue my exploration of the implications from the Department of Justice (DOJ) announcement last week of a new program around Foreign Corrupt Practices Act (FPCA) enforcement, the “Pilot Program”. Contemporaneously, the...more

DOJ Launches FCPA Pilot Program to Encourage Corporate Voluntary Disclosure and Cooperation

On April 5, 2016, the Fraud Section of the Department of Justice's (DOJ) Criminal Division issued an enforcement plan and guidance (the Guidance) laying out three steps it is taking to intensify Foreign Corrupt Practices Act...more

DOJ’s “Half Off” Deals for Self-Reporting FCPA Misconduct: Certain Exclusions Apply, See Below for Details

For the next year, the Justice Department may be offering up to a 50% discount on fines imposed in FCPA cases. Yesterday, the U.S. Department of Justice’s (“DOJ”) Criminal Division announced the launch of a one-year pilot...more

Criminal Division Launches New FCPA Pilot Program

On April 5, 2016, the Department of Justice upped the ante in its efforts to encourage companies to self-report potential Foreign Corrupt Practices Act (“FCPA”) violations when it unveiled a one-year pilot program that...more

Doing Business in Cuba Under the FCPA – Part III

I continue my exploration of the issues raised under the Foreign Corrupt Practices Act (FCPA) when doing or attempting to do business in Cuba. On Monday, I referred to the one person I am aware of you might consult for advice...more

Key Findings from NAVEX Global's Third Party Risk Management Benchmark Report

Vendor risk management and, in particular, third party risk management has become one of the toughest issues companies face—especially after a string of high-profile compliance failures in recent years. The majority of...more

The Importance of Understanding “Corrupt” Intent

All generalizations are false, including this one — Mark Twain Proving intent is a difficult task. White collar crimes turn on the issue of intent – what was in the offender’s mind. With most things in life, people have mixed...more

Prog Rock Week – Part IV: Yes, Close to the Edge and Connected Compliance

Down at the edge, round by the corner. Close to the edge, down by a river. I continue to explore my list of Tom’s favorite prog rock albums by focusing today on the English band Yes. The group dominated prog rock in...more

A Lesson in Compliance: Part II

The following is an interview with Richard Bistrong and Alessia Lamonaca, Program Marketing Specialist at Resolver Inc. In “A Lesson in Compliance with Richard Bistrong: Part I“, Richard discussed the thought process...more

A Lesson in Compliance: Part I

You’ve been quite candid with your followers and readers about your compliance violations and subsequent jail term. One of your blog posts addressed the stark reality you experienced when you first found yourself sitting in a...more

Foundations of Texas and the ROE from a Best Practices Compliance Program

On March 2, we here in the great state of Texas celebrated the 180th founding of our Republic, which occurred in 1836 with the aptly named settlement of Washington-on-the–Brazos, where delegates signed the Texas Declaration...more

The Season of Giving in Asia

Happy New Year of the Monkey! February 8th was the beginning of the two-week long celebration of the Spring Festival, or the Lunar New Year, in China and other countries in Asia. While this season of greetings and...more

VimpelCom Settles FCPA Case – Part III

Today, I continue my exploration of the lessons to be learned from the VimpelCom Ltd. (VimpelCom) Foreign Corrupt Practices Act (FCPA) enforcement action. While it is clear that the company and its Uzbeki subsidiary, Unitel...more

The Force Awakens: Vimpelcom’s FCPA Settlement and the Wreckage Left Behind (Part II of II)

The Vimpelcom FCPA enforcement action is stunning in its breadth and the brazen nature of the bribery scheme. It is hard to accept that such conduct stretched into 2011 to 2013, given the significant emphasis placed on...more

Is There an Internal Ethics & Compliance Council In Us All?

The following guest post and video is by Nicole Rose, CEO and Founder, Create Training. We all know about ‘the law’, but how about the laws within us that direct our behavior and decisions? Marc Hauser, evolutionary...more

First DPA in the U.K. Signals Britain is Serious About Bribery & Corruption

Late last year, ICBC Standard Bank Plc, a U.K.-based financial institution with operations around the world, agreed to pay a $37 million fine and enter into a deferred prosecution agreement (DPA) with British financial...more

Data Analytics Week – Part IV: Third Parties and Duplicate Invoices

I continue my exploration of the use of data analytics in a best practices compliance program. Today we look at how data analytics can be used to help detect or prevent bribery and corruption where the primary sales force...more

Take It Easy – Ruminations on Corruption Scandals in International Sports

As I end my week’s exploration of the intersection of bribery and corruption in international sports, I have also ended a week of solid listening to The Eagles 1970s studio albums. In honor of Glenn Frey, I will also end this...more

Alleged Bribes In Tennis – Why Reporting of Unethical Conduct is Critical

I continue my exploration of bribery and corruption in sports. Today we leave the world of track and field and enter the gentile realm of tennis where there have been recent reports of match fixing and attempted bribery....more

[Webinar] White Collar Crimes in Indo-U.S. context: Do’s and Don’ts - Meritas Capability Webinar - Feb. 3rd, 10:00am EST

While emerging markets represent untapped growth potential and investment opportunities, there is often a sharp contrast between global best practices and compliance requirements and accepted business practices prevalent in...more

Foreign Corrupt Practices Act Enforcement 2016: In Like A Lamb, Out Like A Lion

In 2015, the U.S. Government significantly bolstered its resources dedicated to combat international corporate bribery under the Foreign Corrupt Practices Act ("FCPA"). By announcing the addition of a team of FCPA-dedicated...more

John Lennon and Communicating Across Cultural Boundaries

Yesterday was the 35th anniversary of the death of John Lennon. I was tempted to write this was truly the day the music died but even as I considered it I realized that Lennon’s music no more died on this date in 1980 than...more

Corruption and the Closing Table: How Much Diligence is Due?

It is 2016 (almost). We all have heard about corruption – outrageous tales of money changing hands to enable access to new markets in under-regulated parts of the world, or payments for access to foreign ports, expediting the...more

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