The bottom-line: If you do not conduct a risk assessment, then you should start praying. The FCPA Guidance made it clear – conduct a risk assessment and tailor your compliance program to the risk assessment....more
This week we have focused on distributors and how a company might think through ranking the risk, performing due diligence on and, finally, how to manage distributors going forward. This was spurred on by a discussion that...more
Former Italian Prime Minister Silvio Berlusconi is no stranger to scandal and controversial statements, but lately his words and actions seem to be providing cause for concern outside of the European Union....more
As almost everyone knows, Lance Armstrong spoke for the first time about his performance enhancing drug (PED) use recently on Oprah. On the first night he admitted for the first time that he used PEDs during his seven wins at...more
When Judge Sporkin, the father of the FCPA, assisted Senator William Proxmire in the drafting of the FCPA, he advised Senator Proxmire that a “books and records” provision was all that was needed to address the problem of...more
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