The Foreign Corrupt Practices Act Compliance

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.
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From NH to Hollywood and Compliance Lessons from the Twins-interview with Jay Rosen

I grew up in Manchester, NH which the largest “city” in Southern New Hampshire with 100,000 residents.  We are effectively a bedroom community of Boston, which informs my fervent support of all things Boston: baked beans and...more

Just Say No, the Power of No and Compliance

What is the first thing that you think of about Former First Lady Nancy Reagan? Right up there for me is three things actually Just Say No, which was her campaign against not only drug abuse but also premarital sex in the...more

FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras [Video]

In this episode, Compliance Week Editor-in-Chief Matt Kelly and I discuss the Avon and Alstom FCPA enforcement actions and then take a look at the ongoing Petrobras corruption scandal and what it means for Brazil. ...more

Language Solutions as Preventative Tool in Anti-Corruption Compliance

Ed. Note-I partnered with Merrill-Brink to write a White Paper on the use of local languages as a preventative tool in FCPA, UK Bribery Act and anti-corruption compliance. Today’s blog post is an excerpt from the full article...more

2015 Trends: #5 Regulatory Enforcement Moves Down Market

While ethics and compliance scandals that implicate brand name companies tend to grab the headlines, smaller organizations have always borne the brunt of regulatory enforcement. Over the years, U.S. Sentencing Commission data...more

FCPA Compliance and Ethics Report-Episode 121-FCPA Year in Review, Part II [Video]

In this episode I review the two Opinion Releases, Esquenazi court decision, DOJ communications via speeches on FCPA enforcement. I end with a look at 2015. ...more

Reconciling Sales Strategy With FCPA Compliance

When Ethical Boardroom asked me to contribute an article on the Foreign Corrupt Practices Act (FCPA) and international sales strategies, I thought it might be interesting to include an organisational change dimension in...more

Marx Brothers Compliance Week Continues – The Stateroom Scene and High-Risk

I continue my exploration of the Marx Brothers’ movies by looking at the famous Stateroom scene from the MGM release A Night at the Opera. In researching this I was somewhat stunned to find that the scene was written and...more

What’s the Password for Compliance? Swordfish and Lessons for the CCO

I continue my exploration of the Marx Brothers this week by looking at their most successful commercial film made for Paramount, Horse Feathers. While Duck Soup is and always will be my favorite film due to its overall and...more

Get Your Tootsie-Frootsie Ice Cream; Hiring as Part of Your Compliance Program

One of my great loves is the Marx Brothers. I fell in love with their rapid-fire wiseacre remarks as a teenager and have been enthralled with them since then. I have seen all of their movies, most of their television...more

Uncovering the “Why” in FCPA Compliance Issues [Video]

Jan. 8, 2014 (Mimesis Law) -- With the consequences of FCPA noncompliance ranging from “huge” to “catastrophic,” compliance should be top-of-mind for U.S. companies doing business with third-party intermediaries and...more

December FCPA Enforcement Digest – Let’s Celebrate the New Year with Anti-Bribery Training!

Happy New Year! I hope everyone had a wonderful holiday and a great start to the New Year. With that said, I hope you’re not suffering from the holiday hangover (and I don’t mean the alcohol-induced kind.) After taking...more

FCPA Predictions for 2015 (Part II of II)

The key to being a successful (FCPA) prognosticator is never to keep score. If you do, you are likely to be disappointed. Instead, I follow the strategy of calculated distraction – for example, I predicted last year...more

FCPA Digest - January 2015

In this issue: - Recent Trends and Patterns in FCPA Enforcement - Foreign Bribery Criminal Prosecution Under the FCPA - Foreign Bribery Civil Actions Instituted by the Department of Justice under the...more

Byzantium and the Alstom FCPA Settlement – Part III

Porphyry is a type of stone that was much favored in the Roman world. In a review of several books in the New York Review of Books, entitled “The Purple Stone of Emperors”, Peter Brown looked into the history of the lithic in...more

FCPA Compliance and Ethics Report-Episode 118-the Alstom FCPA Enforcement Action [Video]

In this episode 118, I take a deep dive into the Alstom FCPA enforcement action and its implication for the CCO and compliance practitioner. I also discuss comments from Dick Cassin and the FCPA Professor on the case. ...more

Germany in the World Cup and the Alstom FCPA Enforcement Action – Part II

“It was important that we played our game for 90 minutes.” That line was found in a The Daily Telegraph article entitled “The unthinkable scoreline: Brazil 1, Germany 7” by Jeremy Wilson. It was a quote from Mats Hummels,...more

FCPA Compliance and Ethics Report-Episode 117-the Avon FCPA Enforcement Action [Video]

In this episode I take a deep dive into the recent concluded Avon FCPA enforcement action. ...more

The Avon FCPA Settlement – Part III

Today I conclude my 2014 blog posts with a final look at the Avon Foreign Corrupt Practices Act (FCPA) enforcement action. Before getting to the key lessons that a compliance practitioner may draw from this enforcement...more

Compliance and Contemplation

In December 2013 I returned to my computer, having been “off-line” for a little over fourteen months, and I couldn’t help but noticing the dramatic growth in the fields of legal, regulatory, audit and investigatory practices,...more

FCPA Conference Offers Insights for More Effective Compliance

Agency officials, attorneys and compliance professionals recently gathered to discuss the latest trends and developments in anti-corruption compliance at the American Conference Institute’s annual U.S. Foreign Corrupt...more

The “New Reality” for Corporate Boards

I have very little patience for a corporate board that fails to do its job. A board usually consists of talented, successful and experienced professionals. They have seen good and bad business practices in their days....more

Winter Begins in Valley Forge and the FCPA Professor Teaches in Miami

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

Gifts, Meals and Then . . . FCPA Enforcement

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

Scrooge and Corporate Settlement Agreements

Although there seems to be a difference in the precise publication date between the online reference sites This Day in History and Wikipedia, today we celebrate the Charles Dickens’ work A Christmas Carol, which both sites...more

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