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
Fine Tuning Your Anti Corruption Compliance Program
FCPA Compliance and Ethics Report-Episode 21 Update on Current Enforcement Actions, Investigations and Settlement Negotiations
Trends in FCPA Compliance and Enforcement for 2014
FCPA Compliance and Ethics Report-Episode 14 with the FCPA Professor
The New Normal: Taking Responsibility for Your Vendors
Lessons Learned from the BizJet Executives FCPA Enforcement Actions
It is finally done. The long awaited Avon Foreign Corrupt Practices Act (FCPA) enforcement action is on the books. I would say what a long, strange trip it has been but that does not really seem to capture everything that...more
On December 15, 2014, the Securities and Exchange Commission charged Bruker Corporation with violating the Foreign Corrupt Practices Act by making $230,000 in improper payments to Chinese government officials to win business....more
The Commission brought two FCPA cases this week, one of which was in conjunction with the DOJ. Both centered on the payments for gifts and travel in China.
In addition, the SEC filed three manipulation cases, an action...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
Travel, entertainment and gifts continue to be a central focus of FCPA enforcement. Earlier this month, and last month, the Commission filed settled FCPA actions centered on these items. Now the SEC and the DOJ have settled...more
On December 10, 2014, DOJ filed a criminal Information alleging (i) conspiracy and (ii) violation of the bribery provisions of the FCPA against Dallas Airmotive, Inc., an aircraft engine maintenance, repair and overhaul...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
In this episode Compliance Week editor Matt Kelly and I discuss the COSO 2013 Framework implementation and its changes from the prior Framework. We also discuss the recent Bruker Corp & Dallas Airmotive FCPA enforcement...more
A “world tour” was at the center of FCPA violations by two employees of FLIR Systems, Inc., In the Matter of Stephen Timms, Adm. Proc. File No. 3-16281 (Nov. 17, 2014). Travel was also the focus of the Commission’s latest...more
One hundred and 13 years ago on this date, the first Nobel Prizes were awarded in Stockholm, Sweden, in the fields of physics, chemistry, medicine, literature, and peace. The ceremony came on the fifth anniversary of the...more
As readers of this blog know the FCPA Professor and I usually look at the same Foreign Corrupt Practices Act (FCPA) enforcement action, item or remark and see different things. Sometimes we even hear the same thing and come...more
IN THIS ISSUE:
BSA/AML & OFAC | Virtual Currency & Payment Systems | FCPA & Anti-Corruption | Criminal Enforcement.
The U.S. Department of Justice just issued its most recent Foreign Corrupt Practices Act opinion release, only the second in 2014. The requestor, a publicly traded U.S. consumer products company, sought an opinion as to...more
In this episode I visit with Bill Michael, a partner at MayerBrown on the recent FCPA enforcement action against two FLIR System employees for their excessive payments through gifts, travel and entertainment of certain...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
Improper Gifts Alone, Without Cash Bribes, Serve as Basis for SEC’s Latest FCPA Enforcement Action -
Earlier this week, the SEC announced fines for two former defense contractor employees for FCPA violations relating...more
The Commission filed another settled FCPA action this week. The proceeding named two U.S. citizens living abroad as Respondents. The DOJ issued an Opinion discussing successor liability....more
The Department of Justice (“DOJ” or the “Department”) just issued its most recent FCPA Opinion Release, only the second in 2014. The Requestor, a publicly traded U.S. consumer products company, sought an opinion as to whether...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
The SEC filed another settled FCPA action. The proceeding named two individuals as Respondents. It centers on using expensive gifts and travel as bribes. In the Matter of Stephen Timms, Adm. Proc. File No. 3-16281 (November...more
In this episode, I take a deep dive into the Bio-Rad FCPA enforcement action. ...more
Roderick Hills, who passed away at the end of last month, served as Chairman of the SEC through one if its most turbulent periods – the birth of the Foreign Corrupt Practices Act. When Mr. Hills became Chairman in 1975 the...more
The FCPA enforcement doomsayers can add another notch to their belt – their predictions and suggestions of “enforcement slow downs,” “significant policy changes,” and other misguided claims can be added to the ash heap of...more
As individual jail terms and corporate fines continue to increase, many companies and executives outside the United States are left wondering: How are US laws able to reach so far outside US borders? The United States has...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
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