Risk Mitigation Risk Assessment The Foreign Corrupt Practices Act

News & Analysis as of

A Neglected Compliance Task: Program Assessments

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 [Video]

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

Compliance Reponses to Economic Downturns: A Focus On The Energy Sector

I. The Problem - As I write, oil is hovering around $50 per barrel. The price will inevitably rebound, but all compliance officers need to be prepared for responding to economic downturns in their respective industries...more

Practical Advice on Risk and Compliance Program Assessments

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

COSO and Internal Controls – Part V

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

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

“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

Buying an FCPA Violation Mergers and Acquisition Risks [Video]

FCPA risks are significant when companies acquire other companies. The Justice Department and the SEC have imposed "successor" liability on companies for past bribery violations committed by an acquired company. Pre-closing...more

Trying Something Different – the Desktop Risk Assessment

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 [Video]

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

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

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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