Due Diligence Compliance

News & Analysis as of

What the Government Expects to Find in an Anti-Corruption Compliance Program

Similar to Foreign Corrupt Practices Act enforcement generally, the federal government has expanded what it expects to find in an anti-corruption compliance program. U.S.-connected companies operating internationally...more

Like a Rolling Stone and Charitable Donations Under the FCPA

Today we celebrate one of the seminal achievements in rock and roll for it was on this day, 50 years ago, in 1965 that Bob Dylan recorded his single Like a Rolling Stone. Columbia Records executives initially rejected the...more

The Foreign Corrupt Practices Act: At a Glance

In this issue: - FCPA AT A GLANCE - THE ANTI-BRIBERY PROVISIONS OF THE FCPA - TO WHOM THE ANTI-BRIBERY PROVISIONS APPLY - THE PAYMENT ELEMENT - THE CORRUPT INTENT ELEMENT - WHO IS A...more

FinCEN Fines Michigan MSB For BSA/AML Violations, Bans Owner From Serving at Any U.S. Financial Institution

On May 29, a Michigan-based money service business (MSB), along with its owner, admitted to repeated violations of the BSA and have agreed to pay FinCEN a civil money penalty in the amount of $12,000. The company violated the...more

Export Control Laws for the General Counsel

You are the chief legal officer of a U.S. company. Your CEO walks into your office and announces that your company is about to conclude its first international sale. In addition, the company has just appointed distributors in...more

Federal Reserve Orders Two Financial Institutions to Improve BSA/AML Compliance Programs

On June 1, a Boston-based international financial services holding company and its banking subsidiary agreed to address deficiencies in how they manage compliance risks with respect to their BSA/AML compliance program. The...more

Blog: Post-Incorporation Checklist: 10 Next Steps to Consider

You’ve taken the plunge and formed your business as a Delaware corporation. What do you need to do next? This post, along with the companion piece 8 Legal To-Dos Before Your First Investment, is intended to help you identify...more

Taking Your Business International

Going international is a complicated undertaking. The steps required will depend on your specific situation and concerns. The following outlines, in very general terms, some of the issues you must consider as you begin to...more

FinCrimes Update - May 2015 Summary, Volume 2, Issue 5

FINCEN NAMES JAMES EL-HINDI AS NEW DEPUTY DIRECTOR - On May 21, FinCEN announced Jamal El-Hindi as its new Deputy Director. Since January 2015, El-Hindi has been serving as the agency’s acting Deputy Director, and...more

Will Principles-Based Guidance be Easier to Follow?

Practitioners and market participants often complain that rules and regulations ought to be principles-based rather than prescriptive. In advocating for principles-based regulation, the argument is often made that the...more

Doing Compliance in an Economic Downturn, Part IV – Testing, Peer Groups and Talent Development

Today we celebrate the conquest of what the Tibetans call “Mother Goddess of the Land” and what the rest of us call Mount Everest. For on this date in 1953, Sir Edmund Hillary of New Zealand and Tenzing Norgay, a Nepalese...more

[Webinar] Mid-Sized Companies and Anti-Corruption: How to manage corruption risks with limited resources - May 28, 11:00 am EST

Instances of corruption can have a significant impact on a company’s finances and reputation. With international anti-bribery enforcement actions on the rise, it is essential for companies to implement an anti-corruption risk...more

FCPA Compliance and Ethics Report-Episode 158-Jeff Lurie on pre-acquisition M&A protocols [Video]

In this episode I visit with management consultant Jeff Lurie about his thought for your pre-acquisition protocol when evaluating a company for a merger or acquisition...more

How Smart, Connected Due Diligence Systems are Transforming Third Party Risk Management

The compliance field is in the early stages of a paradigm shift on managing due diligence—moving from a data drought to a data flood. Today’s compliance manager has to figure out how to proactively and continuously manage,...more

DOJ-Mandated Compliance Programs Keep Evolving

Every business with an anti-corruption compliance program needs to know what that system should include. While there are a number of guidelines and model codes that companies can and do look to, for U.S. companies and others...more

Lions and Tigers and Bears – Certifications, Checklists and Standards

The compliance profession continues to rise in importance. Companies are paying more attention to corporate culture and devoting resources to enhance existing compliance operations. This approach is reinforced with each week...more

Anti-bribery compliance in the UK - check for 'red flags' on any acquisition

When one company acquires another, it has long been common practice for the purchaser to carry out commercial due diligence upon the target company. However, anti-bribery and corruption (ABC) due diligence is often overlooked...more

SEC Charges Underwriter and Bankers in Connection with Offering by China-based Issuer A Cautionary Tale of How Bad Facts and Weak...

On March 27, 2015, the U.S. Securities and Exchange Commission (SEC) announced charges against an investment bank and two of its bankers for failing to adequately review and escalate a due diligence report which contradicted...more

Technology is Transforming Third Party Risk Management: Predicting the Future

The definition of “effectiveness” for a third party risk management program is quickly changing — how is your organization keeping up? I usually avoid predicting the future because you are bound to get something wrong. ...more

Expert Testimony May Be Required To Establish CERCLA Innocent Landowner Defense

On January 20, 2015, the United States District Court for the Eastern District of California in Coppola v. Smith, 2015 U.S. Dist. LEXIS 5127, addressed the application of CERCLA’s innocent landowner defense against a somewhat...more

Reminders from the Goodyear FCPA Settlement

FCPA settlements carry with them a basket of compliance and enforcement lessons. The recent Goodyear settlement with the SEC for $16 million carries some important compliance and strategic reminders for ethics and compliance...more

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

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

Human Trafficking and Government Procurement: New Requirements for U.S. Federal Contractors

On January 29, the U.S. Government released a final rule establishing new anti-human trafficking requirements for U.S. government contractors. The rule amends the Federal Acquisition Regulation (“FAR”) and seeks to strengthen...more

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