News & Analysis as of

Supply Chain Compliance

This Week in FCPA-Episode 53, the I left my heart in San Francisco edition

by Thomas Fox on

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Brazilian President Temer comes under corruption fire? 2. The turmoil at FIFA continues as FIFA’s...more

SEC Issues Updated Statement on Conflict Minerals Rule

by Ropes & Gray LLP on

On Friday afternoon, the SEC’s Division of Corporation Finance issued an Updated Statement on the Conflict Minerals Rule (the “Rule”). An updated Statement was widely anticipated. Earlier in the week, on April 3rd, the U.S....more

Case Closed! – The Conflict Minerals Rule Litigation Is Over, but the Drama Continues

by Ropes & Gray LLP on

After 1,627 days and enough law firm memos to deforest a small country, the litigation relating to the Conflict Minerals Rule came to an end yesterday. In this Alert, we discuss what this means for calendar year 2016...more

How to Measure Third-Party Risk Management ROI

by Thomas Fox on

One area that has bedeviled Chief Compliance Officers (CCOs) and compliance practitioners is how to determine the return on investment (ROI) for your compliance program regarding the management of third parties. While it is...more

New DOJ Evaluation – Valuable Document for the Compliance Practitioner: Part II

by Thomas Fox on

Yesterday I began a two-part series on the Department of Justice (DOJ’s) “Evaluation of Corporate Compliance Programs” (Evaluation) posted on the Fraud Section website late last week. The document is an 11-part list of...more

The Trump Administration-Part III: Preparing for a Catastrophe

by Thomas Fox on

Writing in her weekly New York Times (NYT) Fair Game column, in a piece entitled “The Trump Effect: Time To Buckle Up”, Gretchen Morgenson noted, “investors are now scratching their heads trying to figure out what his...more

The naked truth: Why your supply chain could leave you exposed

by Dentons on

If you are a business owner dealing with suppliers, you are potentially at risk of penalty for corruption related offences....more

Hot Topics in Supply Chain Compliance

by Ropes & Gray LLP on

The last few years have seen a proliferation of new supply chain-focused regulations and other compliance obligations, a trend which isn’t likely to abate any time soon. In this Alert, we provide an overview of selected...more

Combatting corruption risk in the Asia Pacific region: What next?

by Dentons on

The election of Donald Trump as the next US president has raised fundamental questions about the role of the United States going forward, and what implications this will have globally. This presents renewed challenges for...more

Volkov on the Evolving Standards for Compliance Programs

by Thomas Fox on

Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more

European Health Care Compliance Challenges (And Solutions)

by Ropes & Gray LLP on

Life sciences and health care companies (“health care companies”) rightly invest a significant amount of time and money into ensuring compliance with health care regulations in the countries in which they are based, but...more

Monster Movie Month: Episode 2 – The Bride of Frankenstein and Upcoming Events

by Thomas Fox on

Welcome to my second installment in this month’s classic monster movie festival. This year I am revisiting the Frankenstein series and today I want to explore and, indeed, honor the second in the series but what many viewers...more

Learn More Next Week on FCPA Compliance and Leadership

by Thomas Fox on

If you are in Houston next Thursday, September 15, and want to hear three of the city’s top compliance practitioners, I invite you to join myself and the members of the Greater Houston Business and Ethics Roundtable (GHBER)...more

An Organizational Response to Global Compliance Challenges

The following is part II of a guest post by Alison Taylor and James Cohen. A consensus has emerged as to what an effective anti-corruption compliance program looks like – its components and success factors. At the same...more

Prog Rock Week – Part IV: Yes, Close to the Edge and Connected Compliance

by Thomas Fox on

Down at the edge, round by the corner. Close to the edge, down by a river. I continue to explore my list of Tom’s favorite prog rock albums by focusing today on the English band Yes. The group dominated prog rock in...more

FCPA Compliance and Ethics Report-Episode 241 on Human Trafficking Compliance

by Thomas Fox on

In this episode I visit with Holland & Knight partner William Shepard on human trafficking compliance. ...more

Thoughts from the SCCE Utilities & Energy Compliance & Ethics Conference

by Thomas Fox on

Ed. Note-today we have a guest post from Mike Snyder of TRACE International (and noted Aggie) on his observations from the recently concluded SCCE Utilities and Energy Conference. I recently attended the SCCE Utilities...more

Food Safety Criminal Prosecutions: When Compliance is a Matter of Life and Death

by Michael Volkov on

Over the last ten to twenty years, we have witnessed the expansion of federal criminal prosecution of health and safety matters. Environmental and food and drug regulatory enforcement has been supplemented by aggressive...more

Compliance Challenge: The Links Between Corruption and Human Trafficking

Companies are increasingly being required to disclose how they assess and respond to the risks of human trafficking in their product supply chains. Statutes like the California Transparency in Supply Chains Act and the U.K....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

Applying Practical Strategies to Supply Chain Risk

by Michael Volkov on

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 and...more

Defining Compliance 2.0: Key Compliance Partners (Part 5 of 5)

by Michael Volkov on

I always use the “Streetcar Named Desire” line to describe the challenges a  Chief Compliance Officer faces – CCOs depend on the kindness of strangers.  It is a little bit of an exaggeration but bear with me. CCOs are not...more

China Doll and FCPA Risk in the Supply Chain

by Thomas Fox on

I was recently in New York and was able to see the theater production of the new David Mamet play China Doll. It stars Al Pacino and it is probably worth it simply to see Pacino on stage. As you might expect from any Mamet...more

The Modern Slavery Act 2015: Transparency Reporting Provisions

by Latham & Watkins LLP on

What do the new UK transparency reporting provisions mean for companies? The UK is at the forefront of the global move to tackle human trafficking and prevent modern forms of slavery by introducing the Modern Slavery Act...more

Modern Slavery Act: How to Comply with the ‘Corporate Provision’

by K&L Gates LLP on

On 29 October 2015, the ‘corporate provision’, section 54, of the Modern Slavery Act (the “Act”), came into force. All businesses in the UK with a global turnover of £36 million will now be required to publish an annual...more

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