The Foreign Corrupt Practices Act Chief Compliance Officers

The Foreign Corrupt Practices Act is a United States Federal law enacted in 1974 to create transparency and prevent bribery for U.S.-based corporations conducting business overseas.
News & Analysis as of

The Eve of Destruction and Tone at the Top – You Are Who Say You Are

In 1965 the single Eve of Destruction was released. It was written by an 18 year old named Phil Sloan and was sung by former member of the New Christie Minstrels named Barry McGuire. To top it off, it was produced by Lou...more

Top Ten International Anti-Corruption Developments for November 2014

For busy in-house counsel and compliance professionals, we have tried to summarize the most important international anti-corruption developments in the past month with links to primary resources. November was definitely a...more

Hiring and Promotion in Compliance – Wait for Great

The role of Human Resources (HR) in anti-corruption programs, based upon the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act, is often underestimated. I come from a HR background and practiced labor law early in my...more

The FCPA Compliance and Ethics Report-Episode 114-Doing Compliance, The Book [Video]

In this episode, I discuss my recently released book, Doing Compliance: Design, Create and Implement an Effective Anti-Corruption Compliance Program...more

Seamus Heaney and Compliance With a Seat at the Table

I have long been fascinated with the Irish poet Seamus Heaney. I came to know him thought his 1999 translation of Beowulf. While I was aware that he had been awarded the 1995 Nobel Prize for Literature, I did not know his...more

Bobby Keys, the Rolling Stones and Establishing Trust

Bobby Keys died last week. What you probably did not know was that Keys was a Texan so we get to claim him. He was the saxophonist for the Rolling Stones and a number of other serious rockers. ...more

2014 Proskauer Hedge Funds and Other Private Funds Annual Review

This year we saw a flurry of regulatory activity targeting investment advisers and hedge funds, private equity funds and other private funds (collectively, private funds). The following annual review is a summary of some of...more

FCPA Compliance and Ethics Report-Episode 111-Virna Di Palma on the TRACE Matrix [Video]

In this episode, I visit with Virna Di Palma on the newly released TRACE Matrix. This is an extremely useful tool to help companies evaluate a wide variety of corruption and bribery risks on a country by country basis. ...more

International News: Focus on Compliance

In This Issue - Welcome to the final issue of International News for 2014. As regulatory oversight of companies—from Sarbanes Oxley and the Dodd-Frank Act to the Foreign Corrupt Practices Act and the UK Bribery...more

Sherlock Holmes and Innovation in the Compliance Function, Part III – The Hound of the Baskervilles

Today we honor Conan Doyle’s third Sherlock Homes novel, The Hound of the Baskervilles. The novel, originally serialized in The Strand from 1901 to 1902, is generally recognized by Sherlockians as the premier Doyle work...more

Making a List, and Checking It Twice… Compliance Tips for Holiday Business Gifts

On November 17, the U.S. Securities and Exchange Commission (SEC) announced that it had sanctioned two former sales employees in the Dubai office of FLIR Systems Inc., a U.S.-based defense contractor, for violations of the...more

FCPA Compliance and Ethics Report-Episode 110-interview with Jonathan Armstrong [Video]

In this episode I visit with Jonathan Armstrong a partner in Cordery in London. He visits with me about his new firm, the equity investment of Lexis/Nexis in his firm and some of the trends he sees in cross-border...more

Sherlock Holmes and Innovation in the Compliance Function, Part I – A Study In Scarlet

Today begins a week of double themed blog-posts. First I am back with an homage to Sherlock Holmes, for it was in the magazine Beeton’s Christmas Annual that the characters Sherlock Holmes and Watson were introduced to the...more

Due Diligence and The Holy Grail — Red Flags

Compliance professionals love to bandy about the term “red flag.” It is a term with infinite meanings depending on the context. A red flag in a money-laundering context is different than a red flag in a corruption context....more

DOJ and SEC Officials Focus on Enforcement, Self-Reporting and Compliance at International FCPA Conference

From November 18 to 19, 2014, the American Conference Institute held its annual U.S. Foreign Corrupt Practices Act (FCPA) conference outside of Washington, D.C. Keynote speakers including U.S. Department of Justice (DOJ)...more

Shoring Up Your Internal Controls to Keep Your FCPA Compliance Program Current

We recently hosted a webinar featuring noted FCPA expert Tom Fox. Tom explained exactly what the DOJ and SEC look for when enforcing the FCPA and how organizations can stay within the FCPA regulations. Jimmy Lin, our VP of...more

How to Avoid a Mousetrap – Resource Reductions in Your Compliance Function

On this day, 62 years ago, “The Mousetrap”, a murder-mystery written by Agatha Christie, opened at the Ambassadors Theatre in London. The crowd-pleasing whodunit has become the longest continuously running play in history,...more

The FCPA Guidance: Still Going Strong at Two

One of the great things about Sunday afternoon is that Mike Volkov posts his Monday blog, when I usually have time to read it when I get the email notification that it is up. Yesterday he wished the Department of Justice’s...more

Anti-Bribery and FCPA Compliance Guide for U.S. Companies Doing Business In India

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 Strategic Use of Compliance

What is your company’s compliance strategy? By this I do not mean what is your company doing to put in a place a best practices anti-corruption compliance program that meets the requirement of the Foreign Corrupt Practices...more

FCPA Compliance and Ethics Report-Episode 108-Supply Chain Under the FCPA [Video]

In this episode I discuss several different risk based models to evaluate your supply chain under the FCPA or UK Bribery Act. ...more

A Holistic Look at Third Party Risks

In the FCPA world, we tend to get myopic. We see complex issues and business operations through the prism of anti-corruption risks. Businesses and Chief Compliance Officers, however, have a very different perspective....more

Chamber of Commerce: Corporations Form the Cornerstone of FCPA Compliance

Recently one of the most unlikely sources for praise of the Foreign Corrupt Practices Act (FCPA) came out to inform us all that corporations are the cornerstone of FCPA compliance and enforcement. You may be surprised to find...more

Opinion Release 14-02: Dis-Linking The Illegal Conduct Going Forward

One of my favorite words in the context of Foreign Corrupt Practices Act (FCPA) enforcement is dis-link. I find it a useful adjective in explaining how certain conduct by a company must be separated from the winning of...more

Atlanta Burns – the Bio-Rad FCPA Enforcement Action – Part III

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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