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

DOJ’s Marshall Miller: You’re All FCPA Lawyers Now

Marshall Miller, the Justice Department’s principal Deputy Assistant Attorney General for the Criminal Division, has been heating up the compliance conference circuit in recent weeks. On September 17th, it was the Global...more

Carlton Fisk, The Homer and Oversight of a Profitable Subsidiary

Today we celebrate one of the great moments in World Series history. At approximately at 12:34 AM on this date in 1975, Carlton Fisk came to bat at the bottom of the 12th, in Game 6 of the World Series between the Boston Red...more

Internal Controls Outside the US – Part IV

This post will conclude a short series I have presented on the issue of internal controls outside the US. I want to conclude by raising some ways in which a compliance professional can work to implement internal controls in a...more

The Mummy and Internal Controls in Locations Outside the US – Part III

Today we celebrate Hammer Film’s version of The Mummy. This was the first film that the Hammer studios made under a license agreement with Universal Pictures, the holder of the copyright of its classic monsters from the 1930s...more

Implementing compliance programme at the emerging markets of the former Soviet Union

Ed. Note-today we have a guest post from Timur Khasanov-Batirov, Chief Compliance Officer at DTEK and Co-Chairman at Compliance Club of the American Chamber of Commerce in Ukraine. It will be a challenge. I mean to...more

Anti-Bribery Training from Coca-Cola: What I Learned About Bribery, Corruption and Responsibly Entering Underdeveloped Markets

A few weeks ago, I had the pleasure of attending the 22nd Annual Ethics and Compliance Conference, hosted by the ECOA. I’m always intrigued by how the topics of a conference tie together; for example, one of the speakers on...more

Steve Bartman and Internal Controls Outside the US, Part II

Today, we note that 11 years ago, Steve Bartman entered the Chicago Cubs Hall of Infamy. For every baseball fan, if there was ever a but for the grace of God, go thee moment the sad saga of Bartman is it. The Chicago Cubs,...more

Ringo, Sir Paul and an Effective Compliance Program

Sometimes the universe converges in ways that are beyond my simple comprehension. This past weekend was one of them. It began a few months ago when I saw an advertisement from StubHub that showed Ringo Starr playing in...more

The Horror of Dracula and Internal Controls in International Locations, Part I

This Friday we celebrate the second in the Hammer Films horror series, which was actually its first offering, based on Count Dracula, entitled “Horror of Dracula”. It starred the famous Hammer Films horror movie two-some of...more

Tribute to Jim McGrath

Ed. Note-Jim McGrath died this week. He was a good friend and a trusted colleague. My thoughts are with his wife, sister and her family and his parents and the rest of us who were privileged to know Jim. ...more

The Origins of the FCPA - Lessons for Effective Compliance and Enforcement - Conclusion

This is the final part of an occasional series. The entire paper will be published by Securities Regulation Law Journal early next year. Conclusion: The FCPA Today - The FCPA was unique in the world at passage....more

The Positive Effects of DPAs and NPAs in FCPA Enforcement

One of the oft-made criticisms regarding the Department of Justice (DOJ) around its enforcement of the Foreign Corrupt Practices Act (FCPA) is its the use of Deferred Prosecution Agreements (DPAs) and Non-Prosecution...more

The Origins of the FCPA: Lessons For Effective Compliance and Enforcement - Part Five

The Congressional debates - The revelations from the Watergate hearings and the Commission’s investigations and enforcement actions sparked two years of Congressional hearings. Those revelations also spawned a...more

Chief Compliance Officer as Chief Persuasion Officer

The roles of a Chief Compliance Officer (CCO) can be many and varied but one role of any successful CCO is that of Chief Persuasion Officer (CPO). I say this because it is often the case that the most a CCO has in his or her...more

The Mitford Sisters and the Compliance Audit

Deborah Cavendish died last week. She was the last surviving member of an extraordinary group of women known as the ‘Mitford Sisters’. They were six daughters of David Freeman-Mitford, the 2nd Baron Redesdale and the former...more

FCPA Compliance and Ethics Report-Episode 96-interview with Karen Schuder on the teaching of business ethics [Video]

In this episode I interview doctoral candidate Karen Schuder on her research into the teaching of business ethics. ...more

2014 Corporate Governance and Compliance Hotline Benchmarking Report Preview: Benchmarking the Health of Your Whistleblower...

It’s that time again! Last week we released the 2014 Corporate Governance and Compliance Hotline Benchmarking Report. This is our 9th year releasing the Benchmarking Report. The full report covers best practices across all...more

Creation of Yosemite and Putting Compliance at the Center of Strategy

On this day in 1890, an act of Congress created Yosemite National Park, home of such natural wonders as Half Dome and the giant sequoia trees. Environmental trailblazer John Muir (1838-1914) and his colleagues campaigned for...more

Third Parties and Red Flags

The following is our second Q & A with Richard Bistrong. In your view why do sales representatives or front line business personnel engage in bribery or hire a third party for the express purpose of paying a...more

Thinking Compliance When Protecting Your Ideas Internationally [Video]

Companies are increasingly seeking international protection for their intellectual property, but in doing so their interaction with foreign government agencies increases. Because of increased scrutiny on corporate compliance...more

Discipline and Rigor in Your Internal Controls

In a recent New York Times (NYT) Op-Ed by David Brooks, entitled “The Good Order”, he discussed how routine can lead to creativity. He cited to the example of three well-known authors whose habits included the following....more

FCPA Compliance and Ethics Report-Episode 95-interview with Scott Killingsworth on Private to Private Compliance Solutions [Video]

In this episode I visit with Scott Killingsworth, partner at BryanCave on his thoughts around the compliance solutions found in private-to-private compliance obligations. ...more

TNG Premiers and Internal Controls for Gifts in a Best Practices Compliance Program

This week, 27 years ago, Star Trek – The Next Generation (TNG) made its television debut. Rarely has there a follow up to a beloved original series (Star Trek – The Original Series (TOS)) that is equally treasured by fans. ...more

More Empty Words for an FCPA Compliance Defense

It is hard to understand why there are still advocates for an FCPA compliance defense. The issue is dead and gone, and is unlikely to come back in any form. I guess there are people who enjoy “zombie” movies – for the life of...more

SEC Announces $30 Million Whistleblower Award to Non-U.S. Resident

On Monday, September 22, 2014, the SEC announced that it expected to award between $30 and $35 million to a non-U.S. whistleblower who provided the SEC with information about “an ongoing fraud that would have been very...more

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