News & Analysis as of

Employer Liability Issues Anti-Corruption

Dentons

Ep. 2 - Why Anonymous Reporting is the Cornerstone of Your Compliance Program

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When was the last time your organization received an anonymous compliance concern?  Has it been so long you can’t recall? Maybe you consider yourself lucky that the organization has never received a concern on your watch, or...more

Littler

Costa Rica Passes First “Whistleblower Law” to Protect Complainants and Witnesses of Possible Acts of Corruption

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On December 13, 2023, the Legislative Chamber of Costa Rica passed Bill No. 23,449, “Protección de las personas denunciantes y testigos de actos de corrupción contra represalias laborales” (Law for the protection of...more

Littler

Proper Planning and Swift Action Can Help Employers Avoid Foreign Corrupt Practices Act Prosecution

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While the Department of Justice (DOJ) has initiated at least two new Foreign Corrupt Practices Act (FCPA) enforcement actions against U.S. companies, it has also announced several decisions not to prosecute—most recently...more

Foley Hoag LLP - White Collar Law &...

First Circuit Narrows Whistleblower Protections of Sarbanes-Oxley

On July 13, 2022, the United States Court of Appeals for the First Circuit ruled that the whistleblower protections contained in Section 806 of the Sarbanes-Oxley Act (SOX) do not apply to employees who report potential...more

Orrick, Herrington & Sutcliffe LLP

Employers to the Rescue? Potential Compliance Risks When Helping Male Employees Leave Ukraine

Companies seeking to help their Ukrainian employees safely exit Ukraine should be aware of potential risks related to the Foreign Corrupt Practices Act (FCPA) and other U.S. laws and regulations. Following Russia’s invasion...more

The Volkov Law Group

Compliance Messaging: Need a Reason? ‘Tis the Season!

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As the holidays quickly approach, consider sending a message from the Board or senior management reminding employees about your gift and hospitality policy....more

A&O Shearman

New EU Directive on Protection of Persons Reporting Breaches of Union Law

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A new EU Directive, known as the "EU Whistleblowing Directive", that aims to enhance the enforcement of EU law and policies by providing protection for individuals that report breaches has been published in the Official...more

Thomas Fox - Compliance Evangelist

Casebook of Sherlock Holmes: The Illustrious Client-the Reference Check

Why is hiring so important for compliance? It is because hiring is important to any company’s health and reputation. Like most areas of compliance good hiring practices for those employees who will do business in compliance...more

Jones Day

Antitrust Alert: European Union May Introduce Whistleblower Protections as Under Sarbanes-Oxley

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Whistleblowers who expose breaches of European Union law will be afforded greater protection from retaliation by companies and public authorities under a draft law proposed by the European Commission in April 2018. The draft...more

Fisher Phillips

For US Employers Operating in Mexico, Anti-Corruption Compliance Now is a Multi-Jurisdictional Obligation

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For several decades, US employers operating in Mexico (or anywhere else around the globe, for that matter) have been subject to – and, therefore, should be aware of – the tenets of the federal Foreign Corrupt Practices Act...more

Pillsbury Winthrop Shaw Pittman LLP

China Aims to Strengthen Regulations on Commercial Bribery

Recently, the Legal Affairs Office of the State Council released draft amendments (Draft Amendments) to the Anti-Unfair Competition Law (AUCL) of the People’s Republic of China (PRC) for public comments. The Draft Amendments...more

Foley & Lardner LLP

Spain Sets a New Milestone with its Corporate Compliance Statute

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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

The Volkov Law Group

Inside and Out: Anti-Corruption Compliance for Joint Ventures (Part II of III)

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A joint venture can create layers and layers of risk for compliance officers. It is always good to start from the inside and work your way out. If your joint venture partner is a state-owned enterprise, or even more...more

The Volkov Law Group

Building an Anti Corruption Compliance Program Practical Steps 2 18 14, 9 02 AM

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Companies face many risks in the anti-corruption enforcement arena. With the growing globalization of anti-corruption enforcement, companies are responding quickly by enhancing their anti-corruption compliance programs. ...more

Thomas Fox - Compliance Evangelist

Code of Conduct, Compliance Policies and Procedures-Part III

Today, I continue with Part III of my four-part series on the best practices surrounding your Code of Conduct and anti-corruption policies and procedures. In this post, I take a look at drafting policies and procedures. I...more

The Volkov Law Group

Mitigating Bribery Risks With Financial Controls

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Anti-corruption compliance is not as hard as it looks. In fact, by taking a step back, compliance professionals can gain insights. At the direction of compliance professionals, companies like to develop and adopt...more

Littler

Brazil's New Anti-Corruption Law: What Every Multinational Employer Should Know

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On August 1, 2013, Brazil enacted Law 12.846, a new anti-corruption law that establishes a comprehensive system of corporate and individual liability for acts of corruption against Brazilian and foreign public officials or...more

Troutman Pepper

New Brazilian Legislation Addresses Bribery By Corporate Entities

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Bill Provides Important Incentives for Corporate Compliance Programs - The millions of Brazilians protesting in recent weeks in cities and towns across Brazil have brought important and far-reaching corruption reform...more

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