News & Analysis as of

Risk Mitigation Compliance The Foreign Corrupt Practices Act

Compliance’s Role in Preventing the Next “WannaCry” Cyberattack

by NAVEX Global on

The global chaos unleashed by the WannaCry ransomware virus reinforces that cyberattacks are not just the problem of IT departments. Compliance must play an integral part of any organization’s cross-functional cybersecurity...more

White Collar Enforcement and the New Trump Administration: Your Top Ten Questions Answered

by Foley & Lardner LLP on

Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more

The Real Explanation for the Record Year for FCPA Enforcement

by Michael Volkov on

All the FCPA prognosticators, predictors and paparazzi have missed the boat on understanding what happened this year – 2016, to make this a record year in FCPA enforcement. As a former public servant for over 20 years, I am...more

CCOs Cannot Ignore C-Suite Risks

by Michael Volkov on

As the headlines continue to point to major misconduct and scandals involving senior corporate executives, compliance officers need to refocus their efforts and address a critical need....more

Coordinating Third Party Due Diligence and Procurement

by Michael Volkov on

Third party risk management is easily one of the most challenging risks for compliance officers. With all the attention and hype surrounding third party risk, companies have marshaled attention and resources to mitigate the...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

My Ten Commandments of Goal Setting

In June, I attended a one-day event at the NYU Stern School of Business, hosted by Ethical Systems and the Behavioral Science and Policy Association. During one session, “Walking the Tightrope: Balancing Incentives to...more

Shakespeare Week – Part I: Henry IV, Part II – Lawyers and Compliance

by Thomas Fox on

What is the most famous line in Shakespeare about lawyers? That is an easy one because lawyer-haters across the world (and lawyer-lovers as well) know it – First thing we do is kill all the lawyers. It comes from Henry IV,...more

2016 Trends #8: Getting Serious About Anti-Bribery & Corruption Efforts and Third-Party Risk Management

by NAVEX Global on

By now, most organizations understand the importance of identifying and addressing any exposure they have to violations of anti-corruption and bribery (ABC) laws. Much attention has been given to recent cases, and to...more

Applying Practical Strategies to Supply Chain Risk

by Michael Volkov on

A Chief Compliance Officer can get so overwhelmed with risks that it is hard to keep their focus on priorities. Risks are everywhere and no compliance program can address every risk – the trick is keeping your eye on the ball...more

Focus on China - October 2015

by McDermott Will & Emery on

Welcome to the third issue of Focus on China Compliance for 2015. According to the FCPA Blog’s October 2015 Corporate Investigations List, China leads the countries reported to be involved in FCPA investigations with 29...more

Bribery and Behaviors from the Front-Lines

Tell me a little bit about your background and how you came to be an anti-bribery consultant. My entry point into the defense business was as a fourth generation family member of what at the time (the mid 80's) was one...more

Latin America Corruption: Keep Calm, Carry On?

by Shearman & Sterling LLP on

Recently, governmental authorities have pursued corruption investigations in Latin America with a vigor traditionally not seen. One potential result is a significant disruption of business. While there are inherent risks in...more

A Neglected Compliance Task: Program Assessments

by Michael Volkov on

The secret of life is honesty and fair dealing. If you can fake that, you’ve got it made. – Groucho Marx - Sometimes compliance practitioners miss the forest from the trees. They can get lost in the details of their...more

FCPA Compliance and Ethics Report-Episode 147-Prof. David Orozco on the use of compliance as a business strategy

by Thomas Fox on

In this episode I visit with Florida State University Professor David Orozco about his recent article on the use of corporate legal as a business strategy and its implications for the compliance practitioner. ...more

Practical Advice on Risk and Compliance Program Assessments

by Michael Volkov on

Sometimes the compliance industry makes things harder than they really need to be. As a result, Chief Compliance Officers are left to modify and transform practices and tools to fit the real world. I understand why CCOs do...more

Making the Case for Compliance Training for Third Parties

by NAVEX Global on

How to make the case for implementing third party compliance training in your organization. A recent article in the San Francisco Chronicle profiled Jay Jorgensen, the new Global Chief of Compliance at Walmart. The...more

COSO and Internal Controls – Part V

by Thomas Fox on

This post concludes my exploration of internal controls and how companies can demonstrate compliance with the internal controls requirement under the Foreign Corrupt Practices Act (FCPA) by adhering to the Committee of...more

COSO and Internal Controls – Part III

by Thomas Fox on

This post continues my exploration of internal controls and how companies can demonstrate compliance with the internal controls requirement under the Foreign Corrupt Practices Act (FCPA) by adhering to the Committee of...more

Germany in the World Cup and the Alstom FCPA Enforcement Action – Part II

by Thomas Fox on

“It was important that we played our game for 90 minutes.” That line was found in a The Daily Telegraph article entitled “The unthinkable scoreline: Brazil 1, Germany 7” by Jeremy Wilson. It was a quote from Mats Hummels,...more

Trying Something Different – the Desktop Risk Assessment

by Thomas Fox on

One type of risk assessment can consist of a full-blown, worldwide exercise, where teams of lawyers and fiscal consultants travel around the globe, interviewing and auditing. However if there is one thing that I learned as a...more

FCPA Compliance and Ethics Report-Episode 72-interview with Michael Rasmussen

by Thomas Fox on

In this episode of the FCPA Compliance and Ethics Report, I interview Michael Rasmussen, the GRC Pundit. As the man who coined the phrase 'GRC' Michael is one of the country's top GRC experts. He talks about the recent OCEG...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

A Prescriptive Guide To Third Party Risk Management

by NAVEX Global on

The recent examples of compliance program credits for Morgan Stanley and Ralph Lauren have demonstrated that, more than ever, an effective compliance program can protect a company from criminal indictment and generate bottom...more

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