FCPA Survival Guide - Step 8 - Investing in Compliance
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
Compliance Tip of the Day – Compliance Lessons from the Albemarle FCPA Enforcement Action
FCPA Survival Guide: Step 1 - Self-Disclosure
All Things Investigations: Compliance Lessons from Gunvor and Trafigura Enforcement Actions
Corruption, Crime & Compliance: Deep Dive into The Trafigura FCPA Settlement
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
Compliance into The Weeds: Trafigura FCPA Enforcement Action
Corruption, Crime & Compliance: Deep Dive into The Gunvor FCPA Settlement
Episode 314 -- A Deep Dive into Gunvor's FCPA Settlement
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 311 -- Tom Fox on FCPA Enforcement: Self Disclosure and Recidivism
Episode 307 -- Sanctions Enforcement Review and Predictions for 2024
Episode 305 -- Deep Dive into SAP FCPA Settlement
Compliance Into The Weeds: The SAP Foreign Corrupt Practices Act Enforcement Action
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
Global companies face extraordinary risks through their reliance on third-party agents, distributors, consultants and vendors/suppliers. Federal prosecutors and regulators have had a record year in FCPA and sanctions...more
The Department of Treasury’s Office of Foreign Asset Control (OFAC) has steadily expanded its influence in the enforcement landscape. Global companies now face a complex regime of sanctions that require careful navigation....more
Hiring third parties to conduct international business is appealing: Foreign business agents, consultants, distributors, and other groups facilitate business by speaking local languages, providing expertise, and accessing...more
Most discussions of why third party due diligence is so important begin with an explanation of indirect liability and the “deliberate ignorance” standard of knowledge the FCPA imposes. With so much focus on anti-bribery it is...more
I am often asked about franchisor liability under the Foreign Corrupt Practices Act (FCPA). Franchising has been a successful model in the US and now many corporations are looking at overseas expansion opportunities....more
Compliance officers face lots of challenges when conducting third-party due diligence. One issue that frequently arises is determining who exactly owns a potential agent or distributor. ...more
Today we honor one of the greatest diplomatic initiatives that occurred in my lifetime, Nixon’s trip to China; where he arrived on this date in 1972. Like most Americans I was caught completely unaware that Nixon was planning...more
What is the risk? Third-party liability for contractors, resellers, agents and supply chain partners is an issue that continues to bedevil corporations who need or choose to use third parties. The headlines and DOJ/SEC...more