Control of a Set-aside Entity
FCPA Compliance and Ethics Report-Episode 157-Training of Third Parties Under the FCPA
Polsinelli Podcast - An International Trade Issue That May Impact Your Business
Protecting IP Through Employment Law
FCPA Compliance and Ethics Report-Episode 91, Internal Controls for Third Parties Under the FCPA, Part II
FCPA Compliance and Ethics Report-Episode 63-Managing the Third Party Relationship Under the FCPA, Part I
While reading the Embraer settlement documents, I read over the facts implicating a senior legal executive and his/her involvement in the Embraer bribery scheme. Truthfully, I had a slight gasp as I read about a fellow lawyer...more
There are five steps in the life cycle of third party management. - Business Justification and Business Sponsor; - Questionnaire to Third Party; - Due Diligence on Third Party; - Compliance...more
I continue my exploration of the use of data analytics in a best practices compliance program. Today we look at how data analytics can be used to help detect or prevent bribery and corruption where the primary sales force...more
Believe it or not, life principles can be used in compliance, especially in due diligence. I always tell my kids that life has a way of setting priorities. As you get older, life becomes simpler and your priorities become...more
In this episode I discuss the training of third parties under the FCPA. I review the DOJ/SEC FCPA Guidance on this issue; the risk ranking of third parties to help deliver your training; the types of training you can utilize...more
Over this week I have looked at some issues related to compensation and methods from other disciplines that a compliance practitioner might use to test and then improve a company’s third party management regime. Today, I want...more
In this episode, I continue my exploration of internal controls around third parties in a FCPA compliance program, with Henry Mixon. ...more
This week, I am continuing my podcast series, on the FCPA Compliance and Ethics Report, on internal controls in best practices anti-corruption compliance program, under the Foreign Corrupt Practices (FCPA), UK Bribery Act or...more
One question often posed to me is how to think through some of the relationships a company has with its various third parties in order to reasonably risk rank them. Initially I would break this down into sales and supply...more
One of treats each month for the compliance professional is reading the GRC Illustrated column by Carole Switzer, President of the Open Compliance and Ethics Group (OCEG), in the Compliance Week magazine. Not only does...more
Robert Sallee died last week. A smoke jumper, he was the last survivor of the Mann Gulch Fire, one of the worst disasters in the history of the US Forest Service. Sallee’s story and that of the Mann Gulch Fire was detailed in...more