The Foreign Corrupt Practices Act UK Bribery Act Dept. of Justice

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

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

The Sky Is The Limit: Escalating Fines, DPA/NPAs And Deterrence

The controversy around punishment and deterrence of corporate misconduct continues to swirl. As fines increase against companies, it is important to ask the question whether the current enforcement scheme adequately punishes...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

How Straight From The Lion’s Mouth Informs Your Hotline

The symbol of Venice is the Lion of St. Mark. The use of this symbol led to the maxim ‘straight from the lion’s mouth’. This adage came about because the Republic of Venice had its own hotline system where citizens could...more

New Risks Associated with Simultaneous U.S. FCPA and U.K. Bribery Act investigations

On November 20, 2013, during a panel presentation at the 30th International Conference on the Foreign Corrupt Practices Act (“FCPA”), current and former prosecutors from the United States and the United Kingdom discussed the...more

Third Party Risk in a Global Environment

Most organizations engage with hundreds, if not often thousands, of third party vendors, suppliers, agents and business partners, creating a daunting and ever-expanding scope of risk. This risk arises from: 1....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

News Corp As Corporate Suspect – Between Scylla And Charybdis?

Yesterday I used the lyrics from Emerson, Lake and Palmer’s song Karn Evil No. 9, First Impression, Pt. 2 - “Welcome Back My Friends, To The Show That Never Ends” as an entrée into the topic of the investigation of JP...more

Welcome Back My Friends To The Show That Never Ends

...“Welcome back my friends” would certainly seem to be an excellent way to introduce today’s topic; that being the stunning report in the Sunday New York Times (NYT), that JP Morgan is under Foreign Corrupt Practices Act...more

My FCPA And Bribery Act Musings Continue

This past week, my second book, “Best Practices Under the FCPA and Bribery Act” was released. Over the past few years I have tried to provide the compliance practitioner with solid information that can be used to implement,...more

FCPA Snapshot – 2012

In 2012, DOJ and the SEC brought 25 new Foreign Corrupt Practices Act (“FCPA”) enforcement actions, a significant decrease from the number of FCPA enforcement actions brought in 2011 (45) and the prolific 2010 (71). However,...more

Don’t Spread Your Compliance Program Too Thin

“You do not want to be spread too thin”. When I heard that phrase a light bulb went off inside my head. It was uttered to me by Jan Farley, the Chief Compliance Officer (CCO) of Dresser-Rand. I asked Jan what he meant by the...more

Manti Te’o and a Second Set of Eyes

One of the strangest news stories over the past couple of months has been the Manti Te’o story. For those few people who have not heard the story, Te’o was fooled (or not) into believing that he was in an online relationship...more

Doing Business In Italy - Step Up Your FCPA Compliance Now

Former Italian Prime Minister Silvio Berlusconi is no stranger to scandal and controversial statements, but lately his words and actions seem to be providing cause for concern outside of the European Union....more

Happy Birthday FT and Welcome Hanson Wade

Yesterday celebrated an auspicious anniversary as it was the 125th anniversary of the British newspaper, the Financial Times (FT), its first issue having been delivered on February 13, 1888. In England, and across the world,...more

The Tube and Updating Your Compliance Policies

2013 is the 150th anniversary of the London Underground, affectionately known as “The Tube.” It truly is one of the great urban architectural marvels of all-time. The oldest sections of the London Underground completed 150...more

The Government's Response to a Proposed Affirmative FCPA Compliance Defense

This month, the DOJ's Lanny Breuer provided a direct response to the U.S. Chamber's call for an affirmative FCPA compliance defense. This article outlines the various components of that response....more

New Charges for News Corp: Are FCPA Charges Just Around the Corner?

Last week charges were brought against Rebekah Brooks, who ran Murdoch’s newspaper holdings in Britain, Andy Coulson, former editor of the now defunct News of the World, and two other former News International employees....more

Frankenstein, Lance Armstrong and FCPA/Bribery Act Compliance

We continue our series focusing on the classic Hollywood monsters from the Universal Pictures era by taking a look at Frankenstein. Unlike Dracula, where Bela Lugosi basically only played his character in one classic picture,...more

Compliance in the Supply Chain – The Lesson of Gibson Guitar and the Lacey Act

I thought about the Astros futility when reading about the Criminal Enforcement Agreement (CEA) entered into by Gibson Guitar Corp (Gibson) for violations of the Lacey Act, which is a 111-year-old law, originally enacted to...more

21 Results
|
View per page
Page: of 1