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

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

West Side Story and GSK In China – Board Oversight and Tone in the Middle

Yesterday, I celebrated the anniversary of one of America’s cultural lows. But today, I am extremely pleased to open with exactly the opposite, that being one of America’s greatest gifts to the performing arts....more

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

This is the fourth part of an occasional series. The first is available here, the second here and the third here. The entire paper will be published by Securities Regulation Law Journal early next year. The volunteer...more

China Bribery Crackdown Underscores the Need for Stronger Compliance Programs and Risk Assessments

Recently, the Chinese government reported that GlaxoSmithKline (GSK) would agree to pay almost $500 million in fines to settle allegations of bribery, and that some former GSK employees would receive prison sentences. While...more

Lessons from GSK in China – Internal Controls, Auditing and Monitoring

One of the questions that GSK will have to face during the next few years of bribery and corruption investigations is how an allegedly massive bribery and corruption scheme occurred in its Chinese operations? The numbers went...more

FCPA Compliance and Ethics Report-Episode 92-Interview with Matt Kelly [Video]

The FCPA Compliance and Ethics Report is out. In this episode I visit with Matt Kelly, editor of Compliance Week about the upcoming Compliance Week Europe and Compliance Week West conferences, the COSO framework and internal...more

When Bribery Pays, People Bribe

As Alison Taylor (Senior Managing Director, Control Risks) stated in a recent Forbes Article, “Compliance and Risk: Clearing the Org Chart Hurdle, “the traditional preventative approach to risk management is proving...more

FCPA Compliance and Ethics Report-Episode 91, Internal Controls for Third Parties Under the FCPA, Part II [Video]

In this episode, I continue my exploration of internal controls around third parties in a FCPA compliance program, with Henry Mixon. ...more

Use of Influence in the Compliance Function

One of the challenges for any Chief Compliance Officer (CCO) is how to influence the conduct and actions in a corporate environment, particularly as compliance is viewed as non-revenue generating and usually does not exist...more

Internal Controls for Third Party Representatives in a FCPA Compliance Program

This week, I am continuing my podcast series, on the FCPA Compliance and Ethics Report, on internal controls in best practices anti-corruption compliance program, under the Foreign Corrupt Practices (FCPA), UK Bribery Act or...more

The Origins of the FCPA: Lessons For Effective Compliance and Enforcement - Pt 3

The foreign payments cases held the organization and the individuals involved accountable while improving corporate governance for the benefit of the shareholders in the future. A series of cases followed the initial filings....more

Four steps to manage your whistleblower complaints

How do you manage your whistleblower complaints? Getting employees to speak up when they see signs of wrongdoing is hard. Many employees struggle with initially "taking the plunge" (because that's how it may feel) for...more

The Origins of the FCPA: Lessons for Effective Compliance and Enforcement: Part Two

The illicit or foreign payments cases - The preliminary inquiry was followed by formal SEC investigations early in 1974. The resulting cases would become known as the “illicit or foreign payments” cases. The focus of...more

Does Your Company’s “Inadequate Compliance Program” Violate Securities Laws?

In a recent matter before the SEC, settlement of an FCPA claim with Smith & Wesson has raised some worrisome new issues for compliance officers. This settlement is noteworthy for two reasons: 1. Small and mid-sized...more

Use of HR in Your FCPA Compliance Program [Video]

In this episode of the FCPA Compliance and Ethics Report, I discuss how HR can help to facilitate your compliance program. ...more

FCPA Compliance and Ethics Report-Episode 87, what are internal controls, Part II [Video]

In this Part II of What Are Internal Controls? I continue my discussion with noted expert Henry Mixon on the basics of internal controls in a best practices FCPA compliance program....more

King Arthur’s Roundtable – The CCO as Chief Collaboration Officer

Many commentators such as Donna Boehme and Mike Volkov often talk about what is required for the position of Chief Compliance Officer (CCO), both in terms of corporate support and skills as a leader of a company’s compliance...more

What Are Internal Controls, Part I [Video]

In this episode of the FCPA Compliance and Ethics Report, I begin a series on internal controls, with noted practitioner Henry Mixon. This is the first part of a two part episode on the basics of what are internal controls. ...more

Review: The Foreign Corrupt Practices Act in a New Era

Broadly speaking, the Foreign Corrupt Practices Act prohibits offering or paying anything of value to a foreign official to obtain or retain business. Recent years have seen a boom in FCPA compliance efforts and enforcement...more

152 Results
|
View per page
Page: of 7