Risk Assessment, FCPA | JD Supra Law News

Practical Suggestions For Conducting Risk Assessments

by Michael Volkov on 5/2/2013

The bottom-line: If you do not conduct a risk assessment, then you should start praying. The FCPA Guidance made it clear – conduct a risk assessment and tailor your compliance program to the risk assessment....more

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

by Soren Lindstrom, Matt T. Morley, Amy Sommers | K&L Gates LLP on 4/11/2013

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

India: The Quixotic Balancing Of Benefits And Risks

by Michael Volkov on 4/11/2013

I used to say – if your business operates in China, you are likely violating the FCPA in one way or another. Permit me to revise my admonition: if your business operates in India, you are likely violating the FCPA in one...more

Three Compliance Interviews on April 3

by Thomas Fox on 4/4/2013

I attended the Dow Jones Global Compliance Symposium over the past couple of days. It was a great conference and kudos to the entire Dow Jones team for putting on a truly memorable event. Day 2 had some interesting speakers...more

The Truth Behind Gifts, Meals And Entertainment Enforcement

by Michael Volkov on 3/29/2013

It is time for everyone to take a deep breath. The DOJ/SEC Guidance could not have been clearer. The message to companies – stop devoting so much time to building, tinkering with, and monitoring their policies governing...more

Don’t Spread Your Compliance Program Too Thin

by Thomas Fox on 3/25/2013

“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

Breaking Bad: When A Good Employee Goes Bad?

by Michael Volkov on 3/19/2013

No matter how strong a company’s compliance program, there is always a risk. No matter how many times employees are trained, complete certifications and are reminded of their FCPA compliance obligations, there is always a...more

How Do You Determine the Gold Standard For Compliance Programs?

by Thomas Fox on 3/14/2013

What is the gold standard for scientific minds? You might not do better than Albert Einstein who was born on this date in 1879. While most lay persons remember Einstein for his theory on special relativity, and his attendant...more

Lessons from Bill Belichick for the Compliance Practitioner

by Thomas Fox on 3/13/2013

I recently read “War Room: The Legacy of Bill Belichick and the Art of Building the Perfect Team” by Michael Holley which is about Bill Belichick, the rise of the New England Patriots and the sophisticated player evaluation...more

Anti-Corruption Compliance Check-Ups

by Michael Volkov on 3/11/2013

The Justice Department’s message is getting through. The two-fisted strategy of aggressive enforcement and public cajoling on the importance of compliance is being heard by the business community. The Justice Department and...more

Transparency Is The Key to Keeping Everyone Rowing Together for Compliance

by Thomas Fox on 3/7/2013

One of the concepts articulated in the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) Guidance was that every company should assess its own risks for bribery and...more

Inside M&A - Winter 2013

by Obiamaka P. Madubuko, Jeffrey Rothschild, Frank Schoneveld, Jake Townsend | McDermott Will & Emery on 2/22/2013

In This Issue: - FCPA Due Diligence is Critical to Avoid Successor Liability in Cross-Border Transactions - China’s Merger Control Rules...more

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

by Thomas Fox on 2/6/2013

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

Establishing an Effective Compliance Program: An Overview to Protecting Your Organization

by Daniel Small, Kwamina Thomas Williford | Holland & Knight LLP on 1/31/2013

In This Issue: - Overview - Standards and Procedures - Organizational Leadership and Culture - Reasonable Efforts to Exclude Bad Actors From Managerial Ranks - Training and Education - Monitoring,...more

The FCPA Guidance on the Ten Hallmarks of an Effective Compliance Program

by Thomas Fox on 1/23/2013

Many commentators are still mining the Department of Justice (DOJ)/Securities and Exchange Commission (SEC) publication, A Resource Guide to the U.S. Foreign Corrupt Practices Act, (the “Guidance”), which was released last...more

Reality Check On Compliance

by Michael Volkov on 1/23/2013

No one will ever call the last twenty years of television the “golden age of television.” I have always turned off “reality” television for one reason – it is boring. For some reason, American television viewers have become...more

The Danger Of A “Paper” Compliance Program

by Michael Volkov on 1/22/2013

The FCPA Guidance contains many important compliance reminders which should be incorporated into every anti-corruption compliance program. Perhaps the most important observation included in the FCPA Guidance was the...more

A Call To Arms: Conduct A Risk Assessment

by Michael Volkov on 12/17/2012

The FCPA Guidance includes some important reminders for compliance practitioners. Most significantly, DOJ and SEC want companies to reinvigorate their risk assessment process. ...more

Home

Legal News

Find a Lawyer

Browse Subjects

Subscribe

Pro Services

For Reporters

Risk Assessment › The Foreign Corrupt Practices Act