FCPA Compliance and Ethics Report-Episode 108-Supply Chain Under the FCPA
On January 29, the U.S. Government released a final rule establishing new anti-human trafficking requirements for U.S. government contractors. The rule amends the Federal Acquisition Regulation (“FAR”) and seeks to strengthen...more
On January 29, 2015, the U.S. Government released a final rule amending the Federal Acquisition Regulation (“FAR”). The final rule reflects changes to proposed amendments originally released in September 2013.
In this episode I discuss several different risk based models to evaluate your supply chain under the FCPA or UK Bribery Act. ...more
Today we celebrate greatness in two areas. The first is in baseball as on this day in 1939, “New York Yankees first baseman Lou Gehrig benches himself for poor play ending his streak of consecutive games played at 2,130....more
We know that you have been considering what business and commercial issues you will face in 2014 (and perhaps beyond) as an Automotive Supplier. But, have you been considering what legal issues you are likely to face? Do you...more
With the recent publication of Form SD, the disclosure form that all companies subject to the Conflict Minerals Rule must file with the Securities and Exchange Commission (SEC), it is a good time to brush up on the Rule’s...more
It is that time of year again when we dust off the compliance crystal ball and take a look at what might be in store for 2014.
1. Executive Order 13627 Changes Government Contracting -
Want a government contract...more
The China Food and Drug Administration (the “CFDA”) recently published a draft regulation, Good Supply Practices for Medical Devices (the “Draft GSP”), for public comment through January 20, 2014. The first-ever regulation...more
What is the risk?
Third-party liability for contractors, resellers, agents and supply chain partners is an issue that continues to bedevil corporations who need or choose to use third parties. The headlines and DOJ/SEC...more
Today we celebrate Thomas Edison. It is not his birthday but the 127th anniversary of Edison announcing his first recording invention, the phonograph. ...more
Today is National Remembrance Day for Veterans who served their country and across the world. In the US we call it Veterans Day....more
Elmore Leonard died this week. He was certainly one of the most prolific authors of the second half of the 20th Century, turning out a book a year for almost 60 years....more
The SEC’s conflict minerals reporting rules became effective January 1, 2013, and those rules impose burdens on companies throughout the automotive supply chain, given how prevalent the so-called “conflict minerals” are in...more
Supply chain compliance is on the government’s enforcement radar like never before. If the recent Executive Order on Trafficking in Government Contracts and final SEC Conflict Minerals Rules were not notice enough, the...more
Yesterday celebrated an auspicious anniversary as it was the 125th anniversary of the British newspaper, the Financial Times (FT), its first issue having been delivered on February 13, 1888. In England, and across the world,...more
With an effective corporate social responsibility (CSR) policy that adequately addresses supply chain issues, a company can better manage legal, reputational and economic risks.
A company risks legal, reputational and...more
I thought about the Astros futility when reading about the Criminal Enforcement Agreement (CEA) entered into by Gibson Guitar Corp (Gibson) for violations of the Lacey Act, which is a 111-year-old law, originally enacted to...more
The California Transparency in Supply Chains Act of 2010 (the “Act”) was enacted into law on September 30, 2010. According to Section 2 of the Act, the Act’s purpose is to “ensure large retailers and manufacturers provide...more
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