News & Analysis as of

The Foreign Corrupt Practices Act UK Bribery Act Fraud

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.

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

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

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

Foreign Corrupt Practices Act 2015 Update

by BakerHostetler on

Despite a decline in enforcement actions by the Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the...more

DOJ Hires Corporate Compliance Program Expert

by Dechert LLP on

In a somewhat surprising development, press outlets reported last week that the U.S. Department of Justice (“DOJ”) has hired a corporate compliance program expert who will work alongside federal prosecutors evaluating whether...more

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

by Dorsey & Whitney LLP on

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

Fraudulent Receipts Pose Risks for Multinationals Operating in China

by Morgan Lewis on

Multinational companies operating in the country should adapt their compliance programs in light of the risk of civil and criminal penalties. Fraudulent official receipts — or "fapiao"(the Chinese word for an official...more

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

by Thomas Fox on

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

by Thomas Fox on

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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