FCPA Compliance and Ethics Report-Episode 109-interview with Bill Michael on the SEC FCPA enforcement action against FLIR employees
FCPA Compliance and Ethics Report-Episode 94-Internal Controls for Gifts, Travel and Entertainment in a FCPA Compliance Program, Part II
Based upon the language of the Foreign Corrupt Practices Act (FCPA), 2012 FCPA Guidance, FCPA enforcement actions and relevant Opinion Releases, and allowing for inflation over the past 40 years, it would appear reasonable...more
Life can be very humbling. The SEC has definitely humbled me. For years now, I have been claiming that companies spend too much time worrying about gifts, meals and entertainment expenses under the FCPA, rather than...more
In this episode of the FCPA Compliance and Ethics Report I continue my visit with Henry Mixon on internal controls for gifts, travel and entertainment in a best practices FCPA compliance program. ...more