The Foreign Corrupt Practices Act UK Bribery Act Anti-Corruption

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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Survey: Anti-Corruption Laws Have Major Impact on Corporate Compliance Policies

With over $1.5 billion in fines assessed by the U.S. Securities and Exchange Commission for violations of the Foreign Corrupt Practices Act (FCPA) since 2010, corruption concerns are playing a larger role in corporate...more

GSK Faces a Bad Day at Black Rock

One of my favorite movies is Bad Day at Black Rock. It is one of the few movies to combine elements of film noir into something approaching a traditional Western. It also attacks directly the prejudice and hate against...more

Life Cycle Management Of Third Parties – Step 5 – Management Of The Relationship

Today ends my review of what I believe to be the five steps in the management of a third party under an anti-bribery regime such as the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act. On Monday, I reviewed Step 1 –...more

Life Cycle Of Third Party Management – Step 2 Questionnaire

Today, I continue my five-part series on the life cycle of third party management under an anti-bribery/anti-corruption regime such the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act, reviewing Step 2, which I label...more

Fostering Anti-Corruption Compliance at the Local Level

As anti-corruption efforts around the globe get more aggressive, more multi-national businesses are implementing best practices to ensure compliance with laws like the U.S. Foreign Corrupt Practices Act (FCPA) and the UK...more

For FCPA Compliance, Tone At The Top Key, Lack of Policies A Difficulty

The number of FCPA enforcement actions brought in recent years has declined. The SEC, for example, reports that in fiscal 2013 it brought 8 cases, compared to 10 in 2012 and 15 in 2011. Nevertheless, those who might be...more

New Anti-Corruption Law to Take Effect in Brazil

With the continued ongoing work to exploit the discoveries in the Lula (Tupi) field and the recently announced 2013 subsalt strike in the Campos and Santos basins off Brazil's southern coast, oil and gas exploration and...more

Keep Your Hand On The Control

I am continually amazed at the seemingly disparate current events which provide tangible lessons for the compliance practitioner. In an article in the New York Times (NYT), entitled “Hearings on San Francisco Crash Set to...more

The Rogue Employee Myth: Prevention And Detection In A FCPA Compliance Program

I cannot think of any criminal enforcement actions against a corporation involving the Foreign Corrupt Practices Act (FCPA) where there was a lone wolf employee engaging in bribery and corruption on his or her own. There...more

Global Connection - November 2013: Anti-Corruption On a Global Scale: The FCPA is No Longer Considered the Only Game In Town

The Global Connection has extensively covered the U.S. Foreign Corrupt Practices Act (“FCPA”) over the years. With the advent of the U.K. Bribery Act, the FCPA was finally having real competition by another country as a...more

What’s New in Anticorruption Enforcement

According to the New York Times, the Securities and Exchange Commission (“SEC”) is investigating potential bribery issues stemming from alleged abuses in JPMorgan’s “Sons and Daughters” hiring program in China. As reported in...more

Financial Controls In A Best Practices Compliance Program

Financial controls are rarely given top billing in an anti-corruption compliance program under the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act. However, it turns out that financial controls are essential to the...more

The Harvest Moon Will Shine A Light On Compliance

The Harvest Moon is generally considered to be the full moon closest to the Autumn Equinox; the day in the fall when night and day are most equal in length. In folklore, the Harvest Moon was a symbol of fruitfulness allowing...more

Corruption Enforcement Goes Global

As BakerHostetler recently reported in its FCPA Mid-Year Update, the phenomenon of parallel prosecutions is gaining popularity as more countries enact and enforce anti-corruption legislation....more

British PM Leads The Fight Against Shell Corporations

One of the critical areas in due diligence for foreign business partners is determining who are the true owners of an entity....more

Legal Issues in International Philanthropy

In this presentation: - Tax Considerations of International Grantmaking in Today’s World - Recent Developments in International Philanthropy – Best Practices - Grants to Foreign Charities -...more

CIS Legal Update - May 2013: Measures Taken to Strengthen Russian Anti-Corruption Laws

Despite Russia’s reputation for corruption, the anti-bribery climate in Russia is evolving. A recent flurry of anti-bribery legislation, as well as Russia’s ratification of the OECD Convention on Combating Bribery of Foreign...more

Preventing Corruption While Protecting Personal Information

Multinational businesses are subject to a patchwork of laws of the various jurisdictions in which they operate. Complying with the myriad rules and regulations can be challenging. Compliance obligations vary from one country...more

Russia Amends Anti-Corruption Law to Require Affirmative Anti-Corruption Compliance Measures

On January 1, 2013, Russia implemented an amendment to its anti-corruption laws that appears to go beyond the reach of both the U.S. Foreign Corrupt Practices Act (“FCPA”) and the U.K. Bribery Act (“UKBA”) to the extent it...more

Anti-Corruption Law And The Oil And Gas Industry: Evolutions In Both Demand Vigilance

Businesses in the oil and gas industry are cautioned to pay careful attention to evolutions in anti-corruption law in the jurisdictions where they operate. The U.S. government has successfully enforced the Foreign Corrupt...more

Anti-Corruption: Effective Compliance Begins with the Assessment of Risks

Virtually every authoritative source of guidance on effective anti-corruption compliance emphasizes the importance of conducting a company-wide “risk assessment.” For example, U.S. authorities have stressed with regard to the...more

Q: Do You Tell The Central Bank What To Do? A: ‘In Which Country’?

Last weekend in the Financial Times (FT) was a report by Tim Burgis of an interview he held over a lunch meeting with the Angolan Isabel dos Santos, who Forbes magazine recently declared “the continent’s first female...more

Dow Jones’ Anti-Corruption Survey: Key Findings

During the past few years, there has continued to be a shift in the amount of attention companies are putting towards corruption concerns and anti-corruption programs. This is evident in the recent survey of 311 compliance...more

Socio-Economic and Cultural Risk Factors That Drive Corruption: A Focus on the ‘Supply Side’ of the Equation

This is the last installment of my three party series regarding Occupational Fraud. One can never lose focus on what I consider the key question as they enter or play within the international arena: What are the...more

Socio-Economic and Cultural Risk Factors That Drive Corruption”: A Focus on the ‘Demand Side’ of the Equation

Yesterday we discussed Occupational Fraud and how, according to the ACFE, survey participants estimated that the typical organization loses 5% of its revenues to fraud each year. Applied to the 2011 Gloss World Product, the...more

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