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The Foreign Corrupt Practices Act UK Bribery 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.

Oh, Hadn’t You Heard? You’re Violating French Law Right Now! France Gets Serieuse about Anti-Corruption

Ok, ok, don’t panic. Maybe not all of the millions of dedicated readers of this blog are in violation. Nevertheless, as of June 1, if your company does business in France, it may be time to check your anticorruption...more

Data Analysis In a Compliance Best Practices Program

by Thomas Fox on

An in-depth look at the use of data analysis in a best practices compliance program under the Foreign Corrupt Practices Act (FCPA), UK Bribery Act or other anti-corruption compliance regime....more

Termination of a Third-Party – Planning Can Reduce the Pain

by Thomas Fox on

The European concern Airbus has been in the news recently for corruption issues. According to an article in the Financial Times (FT), entitled “Airbus sued by middlemen fired following fraud inquiry”, its annual report lists...more

Code of Conduct Week: Part I – Introduction

by Thomas Fox on

I am joined by Eric Morehead as we begin a five-part series on the Code of Conduct, which serves as the foundational document of a compliance program. Morehead is well-known within the compliance community, having worked at...more

Corporate Compliance Programs: US and UK Perspectives

by Dechert LLP on

In today’s regulatory environment, companies face mounting pressure from law enforcement agencies to maintain robust compliance programs to deter and detect misconduct by employees, third-party vendors and business partners....more

French Anti-Corruption Law Reform

Despite signing the OECD anti-corruption Convention in 1997, France has long been perceived as lacking necessary tools for domestic and international anti-corruption enforcement, particularly in comparison to the US Foreign...more

Serious Fraud Office Makes Big Splash with UK Bribery Act Resolution with Rolls Royce

by Michael Volkov on

After years of fits and starts, and promises and disappointments, the Serious Fraud Office and the UK Bribery Act made its initial splash on the anti-corruption enforcement landscape. Since 2011, companies have been...more

The Implications of Insureds’ Illegal Conduct

by Zelle LLP on

Allegations of corporate bribery and corruption are increasingly frequent. According to a recent report by PwC, the World Bank estimates that more than $1 trillion is paid in bribes each year and 55 percent of global CEOs...more

Code of Conduct Training – Now What?

by Michael Volkov on

When it comes to corporate compliance programs, change does not occur quickly. CCOs are extremely pleased with their improved delivery of code of conduct training. Across the board, companies are refining their codes of...more

ISO 37001: Answers to the 5 Questions We’ve Heard Most About the Standard

by NAVEX Global on

It’s been a month since ISO 37001 was published and there are some questions we have heard percolating in the compliance world about what this means. These are the questions we’ve been hearing the most...more

Compliance Isn’t Going Away (and neither should you) – Part I

by Thomas Fox on

Yesterday I presented my views on why I believe that Foreign Corrupt Practices Act (FCPA) enforcement will continue under the new administration. Today, I want to begin a multi-part series (sorry I don’t know how long it will...more

ISO 37001: Why Your Anti-Corruption Policy Needs to Go Global

by Michael Volkov on

Ten years ago the standard anticorruption policy was nearly exclusively FCPA-focused. DOJ and SEC enforcement actions were the primary, if not the only, concern for corporate executives and board members. The UK Bribery Act...more

Financial Services Quarterly Report - Third Quarter 2016: Managing the Compliance Aspects of Private Equity Investments

by Dechert LLP on

International business transactions can be subject to intense scrutiny due to the broad scope of the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, in addition to other similar anti-corruption measures...more

Good-Bye to Arnold Palmer and Revolutionizing Compliance

by Thomas Fox on

The golfing world and the world of beverages lost one of their giants earlier this week. I, of course, refer to golfing and beverage legend Arnold Palmer. The legend around the beverage is that at dinner one evening Palmer...more

For An Effective Ethics and Compliance Program — First, Train Your Board and Senior Executives

by Michael Volkov on

Compliance professionals are familiar with the phrase “tone at the top,” but what exactly does it mean? Unlike other compliance program components, it cannot be easily formalized and implemented in a policy or procedure....more

Hallmark 7-Third-Party Due Diligence and Payments

by Thomas Fox on

There are five steps in the life cycle of third party management. - Business Justification and Business Sponsor; - Questionnaire to Third Party; - Due Diligence on Third Party; - Compliance...more

Hallmark 4- Risk Assessments

by Thomas Fox on

One cannot really say enough about risk assessments in the context of anti-corruption programs. Since at least 1999 the DOJ has said that risk assessments that measure the likelihood and severity of possible Foreign Corrupt...more

Hallmark 1 – Commitment from Senior Management and a Clearly Articulated Policy Against Corruption

by Thomas Fox on

Over the next two weeks I will be revisiting the Ten Hallmarks of an Effective Compliance program, as laid out in the 2012 A Resource Guide to the U.S. Foreign Corrupt Practices Act ( FCPA Guidance) authored by the Criminal...more

India Supreme Court Clarifies Standard for Enforcement of Indian Prevention of Corruption Act

by Ropes & Gray LLP on

Earlier this year, the Supreme Court of India clarified the standard necessary to prove violations of India’s Prevention of Corruption Act, 1988 (“PCA”), in a ruling that may limit enforcement of the PCA and that has...more

Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA) / FCPA Digest - July 2016

by Shearman & Sterling LLP on

Shearman & Sterling’s bi-annual Trends & Patterns report provides insightful analysis of recent enforcement trends and patterns in the US, the UK, and elsewhere as well as helpful guidance on emerging best practices in FCPA...more

Battle of the Somme Week – Part III: Lessons from Brexit

by Thomas Fox on

There have been a plethora of new books about the Battle of the Somme. Daniel Todman reviewed several in an article for the Financial Times (FT), entitled “Stories of the Somme”. One of the books reviewed, Breakdown: The...more

The UK Bribery Act: SFO Procedures and DPA Process

by Thomas Fox on

A couple of recent articles about the UK Serious Fraud Office (SFO) caught my attention. One was on thebriberyact.com, entitled “Opinion: DPA’s must show greater benefits. We discuss the Criteria & Process for a DPA set out...more

A COSO Look at Control Objectives

by Thomas Fox on

Brian Christensen, in an article in Corporate Compliance Insights (CCI) entitled “The Updated COSO Framework: Time for a Fresh Look at Internal Control”, said that the updated 2013 COSO Framework retained the core definition...more

Corruption Risks and Corporate Social Responsibility Spending

by Michael Volkov on

Global companies have been embracing socially responsible spending projects to build stronger relationships with local communities. The idea makes a lot of sense and real projects can result in real benefits....more

Top Ten International Anti-Corruption Developments for April 2016

by Morrison & Foerster LLP on

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

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