News & Analysis as of

Supply Chain The Foreign Corrupt Practices Act

Private Equity and the New Trump Administration: Your Top Ten Questions Answered

by Foley & Lardner LLP on

The election of President Trump contained some positive signs for Private Equity (PE) fund managers. These included potential lower corporate taxes, a ten-percent tax holiday for funds parked overseas, large infrastructure...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 Administration Ramps up Enforcement Efforts

by Foley & Lardner LLP on

The Trump administration has vowed to bring jobs back to the states. One of the methods it appears it’ll take advantage of is continued, aggressive enforcement of U.S. laws governing exports and international conduct....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

Don’t Let Forced Labor and Bribery in Your Supply Chain Spoil the Holidays

by Perkins Coie on

The holiday retail season is an ideal time to check that forced labor and bribery—two top and interconnected supply-chain threats—do not undermine the success of your critical sales period. Not long ago, many in the...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

Rethinking Stakeholder Engagement for the New Millennium – Part I

by Thomas Fox on

What does stakeholder engagement mean in the 21st century? How has the topic gained such traction over the past few years? What is the role of the compliance professional in stakeholder engagement? How does increased...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

The How Question in Due Diligence

by Thomas Fox on

What is satisfactory due diligence under the Foreign Corrupt Practices Act (FCPA)? That question seems to be more important after the Huffington Post’s story on Unaoil and the subsequent release of the Panama Papers. However,...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

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

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

Five on Friday – Five Recent Developments that We’ve Been Watching Closely

It’s Friday and time for another overview of developments in the field of business and human rights that we’ve been monitoring. This week’s post includes: recent developments with regard to a major Alien Tort Statute...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

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

Compliance Connected – Line of Sight, Part II

by Thomas Fox on

Today I continue my exploration of the line of sight theory under which a Chief Compliance Officer (CCO) or compliance practitioner would have visibility across the lifecycle of a sales transaction so they could move from...more

What Goes Downhill May Go Uphill in FCPA Compliance

by Thomas Fox on

Usually the question I am posed is how far down the chain must you go in your due diligence to ensure that your suppliers are in compliance with the Foreign Corrupt Practices Act (FCPA). I would pose that now, after the...more

Commodore Perry and Integrating Compliance into the Fabric of Your Company

by Thomas Fox on

On this day in 1853, Japan took the initial steps to join the community of nations when US Commodore Matthew Perry, representing the US government, sailed into Tokyo Bay. After due consideration, Japanese officials accepted...more

Fraud and the Detection of the Sources for Bribery

by Thomas Fox on

In a recent White Paper authored by Peter Smith for OFS Portal, entitled “Procurement and Fraud in the Supply Chain”, where he examined “fraud linked to procurement and supply chain activities.” Smith focuses on where fraud...more

FCPA Compliance and Ethics Report-Episode 169-the First Mailbag Issue [Video]

by Thomas Fox on

In this inaugural Mailbag Episode, I field questions from an earlier podcast on the training of third parties under the FCPA. ...more

Taking Your Business International

by Carlton Fields on

Going international is a complicated undertaking. The steps required will depend on your specific situation and concerns. The following outlines, in very general terms, some of the issues you must consider as you begin to...more

Managing Your Third Parties in a FCPA Compliance Program

by Thomas Fox on

The building blocks of any Foreign Corrupt Practices Act (FCPA) anti-corruption compliance program lay the foundations for a best practices compliance program. For instance in the lifecycle management of third parties, most...more

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