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Corruption Due Diligence

Thomas Fox - Compliance Evangelist

The Bre-X Mining Scandal, Part 1: A Scandal for the Ages

Few corporate scandals are still as infamous or devastating as the Bre-X mining scandal. What began as a story of incredible wealth, fueled by the promise of one of the largest gold deposits ever discovered, unraveled into...more

Benesch

White Collar Quarterly Report - August 2024

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In 2023, the number of federal corporate prosecutions remained far below the 25-year average after two consecutive years of increases. ..The DOJ’s Fraud Section secured just $690 million in penalties across eight...more

Cadwalader, Wickersham & Taft LLP

Cadwalader Climate - July 2024 #4

In this week’s edition we discuss the implications of a decision against the National Crime Agency, which the UK’s Court of Appeal held had misinterpreted the law when it refused to investigate whether imported cotton was...more

NAVEX

What a New SEC Enforcement Sweep Is Really Telling Us

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Attention all compliance officers at large technology companies – have you checked your mail lately? Because you might find a letter from the Securities and Exchange Commission with FCPA risk written all over it....more

Mintz

EnforceMintz — DOJ’s Efforts in 2023 to Incentivize Voluntary Self-Disclosure

Mintz on

2023 was a very active one for Department of Justice (DOJ or the “Department”) guidance, and that guidance had one clear theme: DOJ wants companies to voluntarily self-disclose their misconduct. To incentivize...more

Society of Corporate Compliance and Ethics...

Third-party due diligence: Are supplier questionnaire(s) the answer?

Numerous laws (U.K. Bribery Act guidance document, German Supply Chain Act, Foreign Corrupt Practices Act resource guide, OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and...more

Thomas Fox - Compliance Evangelist

Levels of Due Diligence

Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of corruption risk. The key is to develop a mechanism to determine the appropriate level...more

Walkers

AML update: JFSC announces its focus on PEPs in January 2024

Walkers on

The Jersey Financial Services Commission ("JFSC") recently announced that its first area of focus for its 2024 thematic examination programme will be politically exposed persons ("PEPs") (the "Examination"). The Examination...more

Paul Hastings LLP

Good Governance and The Future Scope of Human Rights Due Diligence

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As we transition into an era of human rights due diligence mandated by regulation, many in the business and human rights community are nervously asking the same question. Will a company’s steps to identify and address actual...more

Troutman Pepper

The Stick and the Carrot: DOJ Continues to Eye Corporate Crimes, While Encouraging Prompt Self-Disclosures of Misconduct...

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On October 4, Deputy Attorney General (DAG) Lisa Monaco announced the Department of Justice’s (DOJ) new Safe Harbor Policy for voluntary self-disclosures made in connection with mergers and acquisitions (M&A). This policy is...more

Robinson & Cole LLP

DOJ Announces Extension of Voluntary Self-Disclosure Guidance for Misconduct Discovered Through M&A Due Diligence

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On October 4, 2023, the U.S. Department of Justice (DOJ) announced a uniform approach for the resolution of voluntary self-disclosure (VSD) of misconduct discovered during M&A due diligence. The Mergers & Acquisitions Safe...more

Ankura

Saving Football From Dubious Owners Is Not an Easy Task

Ankura on

Football is an industry built on passion and commitment, with clubs steeped in tradition and soaked in the hopes and dreams of supporters captivated by the rollercoaster of emotions that professional sports can bring. It...more

American Conference Institute (ACI)

[Event] 9th Anti-Corruption and Corporate Social Responsibility Conference - October 9th - 10th, Puteaux, France

Hosted by C5 Group, the 9th Anti-Corruption Conference in Paris returns for another exciting year with curated programming that will shed light on important issues at the forefront....more

American Conference Institute (ACI)

[Event] 13th West Coast Forum on FCPA Enforcement and Compliance - June 14th - 15th, San Francisco, CA

Hosted by American Conference Institute, the 13th West Coast Forum on FCPA Enforcement and Compliance returns for another exciting year, providing the opportunity to connect with decision-makers from your industry, gather...more

The Volkov Law Group

Flutter Entertainment Settles SEC FCPA Case for $4 Million for Improper Payments to Russian Consultants

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Flutter Entertainment, the previous owner of PokerStars, agreed to pay the Securities and Exchange Commission $4 million for improper payments to Russian-based consultants, stemming from conduct committed by The Stars Group,...more

Thomas Fox - Compliance Evangelist

Levels of Due Diligence-Part II

In the conclusion of this blog post series on levels of due diligence, I am drawing from Candice Tal, Founder and CEO of Infortal Worldwide, in her seminal article entitled, Deep Level Due Diligence: What You Need to Know....more

Oberheiden P.C.

Internal Audit for FCPA Compliance: A Detailed Guide

Oberheiden P.C. on

The Foreign Corrupt Practices Act (FCPA) (15 U.S.C. § 78dd-1 et seq.) is a federal anti-bribery law that makes it unlawful for certain people to pay foreign government officials in order to conduct business abroad. While it...more

White & Case LLP

Corporate Liability for Terrorist Financing

White & Case LLP on

Terrorist financing comes at a price – and in the case of a global building supplies manufacturer that has pleaded guilty in a US court to making payments to terrorist organisations, that price is USD 778 million in fines and...more

Society of Corporate Compliance and Ethics...

[Event] 11th Annual European Compliance & Ethics Institute - March 20th - 22nd, Amsterdam, Netherlands

In-person is back! Join us in Amsterdam for the 2023 European Compliance & Ethics Institute! Strengthen your compliance and ethics program by attending our 11th annual European Compliance and Ethics Institute, 20-22 March...more

K2 Integrity

ESG Certification: Assisting in Mitigating Greenwashing for Investors, Managers, Funds and Regulators

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There have been numerous positive developments in the evolution of ESG investing. Still, the research needed to assess which investments are truly ESG-compliant and which are tantamount to greenwashing is burdensome...more

Society of Corporate Compliance and Ethics...

Rethinking bribery

CEP Magazine (March 2022) - In November 2021, the Organisation for Economic Co-operation and Development (OECD) issued a significant update to its guidance on combating bribery of foreign public officials, replacing its...more

Society of Corporate Compliance and Ethics...

[Virtual Event] ESG and Compliance Conference - April 26th, 7:55 am - 3:15 pm CDT

Discover how to set and accomplish your ESG goals - Environment, Social, and Governance (ESG) is no longer an isolated function within a company, nor is it an issue only for publicly traded companies. It’s front and...more

The Volkov Law Group

Lessons Learned from the KT Corp. SEC FCPA Settlement (Part III of III)

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Even though the size of the KT Corp. SEC enforcement action is relatively small, the underlying misconduct provides a number of important lessons learned. ...more

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Join the Go-To Event of the Year for Mexico’s Anti-Corruption Community. The annual ACI’s Anti-Corruption Summit in Mexico is back to Mexico City on March 22-23, 2022! This is the most important anti-corruption compliance...more

K2 Integrity

What the Private Sector Can Do About Corruption in 2022

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In its most recent Corruption Perceptions Index (2020), which ranks countries by their perceived levels of public sector corruption, Transparency International found more than two-thirds of countries around the world fell in...more

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