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Corruption The Foreign Corrupt Practices Act

AI for Risk Management in Compliance – A New Business Advantage

by Thomas Fox on

There have been some articles recently which discussed the revolution of technology into compliance, specifically with the introduction of Artificial Intelligence (AI) into the profession. A few pieces claimed this was...more

2016 Could Be Peak SEC

2016 was a high-water mark for SEC enforcement activity; however, with the uncertainties associated with the new administration’s enforcement regime, we could be seeing a downturn going forward. According to a recent report...more

The FCPA at 40 – FCPA Enforcement and the International Fight Against Bribery

by Thomas Fox on

In two speeches last week Department of Justice (DOJ) Acting Principal Assistant Attorney General Trevor McFadden addressed multiple topics and issues around the Foreign Corrupt Practices Act (FCPA). The first set of remarks...more

The FCPA at 40 – Corporate Responsibility for Compliance

by Thomas Fox on

In two speeches last week Department of Justice (DOJ) Acting Principal Assistant Attorney General Trevor McFadden addressed multiple topics and issues around the Foreign Corrupt Practices Act (FCPA). The first set of remarks...more

The FCPA at 40 – Evolution in the Fight Against Bribery and Corruption

by Thomas Fox on

In two speeches last week Department of Justice (DOJ) Acting Principal Assistant Attorney General Trevor McFadden addressed multiple topics and issues around the Foreign Corrupt Practices Act (FCPA). The first set of remarks...more

Talking About Bribery in the Country Where I Bribed

I recently returned from a week in Amsterdam, addressing front-line compliance challenges, and attending several anti-corruption conferences. It was a surreal experience for me, for in 2003 I paid a “Dutch Agent approximately...more

Top Ten International Anti-Corruption Developments for March 2017

by Morrison & Foerster LLP on

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Termination of a Third-Party – Planning Can Reduce the Pain

by Thomas Fox on

The European concern Airbus has been in the news recently for corruption issues. According to an article in the Financial Times (FT), entitled “Airbus sued by middlemen fired following fraud inquiry”, its annual report lists...more

Long-Running Corruption Scheme Exposed in Brazil: Operation "Exposed Invoice" Provides Continuous Improvement Opportunity for...

by Pepper Hamilton LLP on

A massive scheme involving medical products sales to Brazilian public entities has led to recent high-profile arrests. The events highlight the importance to a well-functioning compliance program of keeping up with new...more

Top bribery and corruption developments in 2017 for ADG companies

by Hogan Lovells on

In recent years, U.S. and Western European military spending has decreased as military spending in other parts of the world has risen. As a result, aerospace, defense and government services (ADG) companies increasingly rely...more

Code of Conduct Week: Part III – Design of Your Code of Conduct

by Thomas Fox on

Today I continue my Code of Conduct exploration with Eric Morehead, Principal of Morehead Compliance Consulting. After having reviewed the legal requirement and business purpose in Part I, the structure and form of your Code...more

A Strategy for Non-Disclosure of FCPA Violations

by Michael Volkov on

We all understand that issues are not black and white, meaning there are areas of gray when analysis and cost-benefits need to be weighed. Lawyers are regularly identifying legal risks and applying such risks to specific...more

Trump and the FCPA: Perception Is Not Reality

by Holland & Knight LLP on

Many have questioned whether President Donald Trump, who as a businessman called the Foreign Corrupt Practices Act (FCPA) a "horrible law" in 2012, would seek to change the law, its enforcement or both. However, recent...more

FCPA Remediation Focus on Supervisory Personnel

by Michael Volkov on

The Justice Department’s FCPA enforcement and remediation focus on supervisory personnel is an interesting development. On the one hand, DOJ has been slow to bring individual criminal enforcement actions for FCPA...more

Brazilian Corruption Scandals Continue

by Thomas Fox on

The stench of corruption continues to bedevil Brazil, even as the clean-up initiated with Operation Car Wash is ongoing. This time, allegations of bribery and corruption have reached one of Brazil’s most prestigious exports,...more

LRN Compliance Program Effectiveness Report: Part III

by Thomas Fox on

This week I have been considering the LRN Corporation’s 2016 Ethics and Compliance Program Effectiveness Report (LRN Report) by outlining some of its general findings. Today, I want to conclude by using the Report as a road...more

LRN Compliance Program Effectiveness Report: Part II

by Thomas Fox on

Yesterday I began a series on the LRN Corporation’s (LRN) 2016 Ethics and Compliance Program Effectiveness Report (Report) by outlining some of its general findings. Today, I want to focus on its detailed findings as it...more

Understanding the New DOJ Guidance: Part 1 – Tone at the Top

In February, the Department of Justice’s Fraud Section offered a new perspective on what the government expects in a compliance program in the form of a series of questions that companies should be prepared to answer about...more

Justice Department Reveals How It Evaluates Corporate Compliance Programs

by Holland & Knight LLP on

The U.S. Department of Justice (DOJ) Fraud Section recently published its "Evaluation of Corporate Compliance Programs" that lists 1) the topics it explores and 2) the questions it asks when it assesses the effectiveness of a...more

Rules of the (International) Road

by Carlton Fields on

Going international is a complicated undertaking. Your specific situation and concerns will determine the steps required. The following outlines, very generally, some issues you must consider as you contemplate international...more

LRN Compliance Program Effectiveness Report: Part I (and Farewell to Chuck Berry)

by Thomas Fox on

Last week I interviewed Susan Divers, Senior Advisor at LRN Corporation, on the company’s 2016 Ethics and Compliance Program Effectiveness Report (Report). The Report was a fascinating review of the evolution of compliance...more

FCPA Pilot Program Motors On

by Michael Volkov on

No one was really surprised when Kenneth Blanco, Acting Assistant Attorney General for the Criminal Division, US Department of Justice, announced last week that DOJ was planning to continue the FCPA Pilot Program past April...more

FCPA: 2016 Year in Review & 2017 Enforcement Predictions

by Bass, Berry & Sims PLC on

Bass, Berry & Sims announces the release of its "FCPA: 2016 Year in Review & 2017 Enforcement Predictions," a review of trends and developments in FCPA as well as a look ahead into what to expect for 2017. The newly released...more

FCPA Compliance Report-Episode 313-Adam Davidson on Donald Trump's Worst Deal [Video]

by Thomas Fox on

In this episode, I visit with New Yorker reporter Adam Davidson, who penned an article in the New Yorker which looked at a hotel deal between the Trump organization and a family of Politically Exposed Persons (PEPs) in...more

Top Ten International Anti-Corruption Developments for January 2017

by Morrison & Foerster LLP on

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

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