FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras
FCPA Compliance and Ethics Report-Episode 121-FCPA Year in Review, Part II
Government’s Health Care Fraud “Cash Cow” Keeps Mooing
FCPA Compliance and Ethics Report-Episode 119-FCPA Year in Review, Part I
FCPA Compliance and Ethics Report-Episode 118-the Alstom FCPA Enforcement Action
FCPA Compliance and Ethics Report-Episode 117-the Avon FCPA Enforcement Action
FCPA Compliance and Ethics Report-Episode 115-Tom Fox and Matt Kelly on COSO, Bruker Corp, Dallas Airmotive and Alstom
FCPA Compliance and Ethics Report-Episode 109-interview with Bill Michael on the SEC FCPA enforcement action against FLIR employees
FCPA Compliance and Ethics Report-Episode 107 the Bio-Rad FCPA Enforcement
FCPA Compliance and Ethics Report-Episode 105-interview with Barry Vitou
Anti-Corruption Due Diligence Practical Steps to Protect Your Company from Third Party Risks
Creating an Integrated Due Diligence System - Screening to Audits
Third Party Due Diligence When is Enough, Enough?
An FCPA Review: A Look Back at 2013 and Trends for 2014
How Can You Better Protect Yourself with the Escalating Trend of FCPA Enforcement?
AML BSA and Sanctions Compliance Part II of II June 24, 2014
Thomson Reuters Session - April: Investment Management, Hedge Funds & Registered Mutual Funds: What's Happening Now?
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
Building an Integrated Third Party Due Diligence System Initial Screening to Audits
In this episode, Compliance Week Editor-in-Chief Matt Kelly and I discuss the Avon and Alstom FCPA enforcement actions and then take a look at the ongoing Petrobras corruption scandal and what it means for Brazil. ...more
In this issue:
- New Law Aligns Clearing and Margin Exceptions for Swaps
- CFTC Staff Extends No-Action Relief to Certain Reporting Counterparties Masking Identifying Information Pursuant to Non-US Law
Recently, FinCEN announced a $1 million civil money penalty against the former Chief Compliance Officer (CCO) of a large financial services company for allegedly violating the Bank Secrecy Act (BSA) and its implementing...more
I am at the end of my week of Marx Brothers themed posts. As you can tell, I am a huge fan and several of you have asked which is my favorite film. Before answering I must confess that I much prefer their Paramount films to...more
While ethics and compliance scandals that implicate brand name companies tend to grab the headlines, smaller organizations have always borne the brunt of regulatory enforcement. Over the years, U.S. Sentencing Commission data...more
In this episode I review the two Opinion Releases, Esquenazi court decision, DOJ communications via speeches on FCPA enforcement. I end with a look at 2015. ...more
Happy New Year! I hope everyone had a wonderful holiday and a great start to the New Year.
With that said, I hope you’re not suffering from the holiday hangover (and I don’t mean the alcohol-induced kind.) After taking...more
The key to being a successful (FCPA) prognosticator is never to keep score. If you do, you are likely to be disappointed.
Instead, I follow the strategy of calculated distraction – for example, I predicted last year...more
In this issue:
- Recent Trends and Patterns in FCPA Enforcement
- Foreign Bribery Criminal Prosecution Under the FCPA
- Foreign Bribery Civil Actions Instituted by the Department of Justice under the...more
Porphyry is a type of stone that was much favored in the Roman world. In a review of several books in the New York Review of Books, entitled “The Purple Stone of Emperors”, Peter Brown looked into the history of the lithic in...more
In this episode 118, I take a deep dive into the Alstom FCPA enforcement action and its implication for the CCO and compliance practitioner. I also discuss comments from Dick Cassin and the FCPA Professor on the case. ...more
“It was important that we played our game for 90 minutes.” That line was found in a The Daily Telegraph article entitled “The unthinkable scoreline: Brazil 1, Germany 7” by Jeremy Wilson. It was a quote from Mats Hummels,...more
In this episode I take a deep dive into the recent concluded Avon FCPA enforcement action. ...more
Today I conclude my 2014 blog posts with a final look at the Avon Foreign Corrupt Practices Act (FCPA) enforcement action. Before getting to the key lessons that a compliance practitioner may draw from this enforcement...more
Today we celebrate one of the seminal turnarounds in US history for on this day in 1777, George Washington lead his beleaguered troops into winter quarters at Valley Forge, Pennsylvania. At that point in time, things could...more
Life can be very humbling. The SEC has definitely humbled me.
For years now, I have been claiming that companies spend too much time worrying about gifts, meals and entertainment expenses under the FCPA, rather than...more
The U.S. Foreign Corrupt Practices Act of 1977 (“FCPA”) presents significant liability, risks, and compliance challenges for U.S. firms pursuing business opportunities in India.
U.S. regulators have brought numerous...more
The Fourth Quarter of 2014 has been a busy one for DOJ and SEC in the FCPA arena. We are all praying that DOJ and SEC resolve the Avon case soon so that we do not have to include the case on our lists for predictions for...more
In this episode, I take a deep dive into the Bio-Rad FCPA enforcement action. ...more
On this date in 1864, the Union Army phase of the destruction of Atlanta began. While most Southerners credit Union General William T. Sherman with the burning of Atlanta, it was, in reality, Confederate General John Bell...more
Below is an update on the lawsuits we have been following that state attorneys general and a state regulator have brought using their Dodd-Frank enforcement authority. Under Dodd-Frank Section 1042, a state AG or regulator is...more
John Doar died yesterday. He was perhaps most famously known for his role as the House Judiciary Committee Chief Counsel during the investigation of and impeachment proceedings against then President Nixon. However, it was...more
In this issue:
- Bank Prudential Regulation & Regulatory Capital
- Consumer Protection
- Financial Services
Raising capital through crowd-funding is one of the key provisions of the JOBS Act. It is supposed to facilitate raising small amounts of capital for start-up operations. An off-shore crowd-funding site that sold unregistered...more
The U.S. Securities and Exchange Commission recently settled the first securities fraud charges brought against a municipal official alleging “control person” status under the federal securities laws. The SEC’s settlement...more
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