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
Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more
Ericsson’s FCPA settlement is in the books (not the books and records). But it casts a significant shadow across the FCPA landscape. A pervasive and systemic culture of bribery is defined to reflect senior executive...more
Believe it or not, but companies are still struggling with third-party risk management systems. I know this sounds hyper-critical but many companies continue to hang onto paper due diligence systems (sometimes with or...more
The first lesson for the compliance practitioner is that you should actually test your compliance program in high-risk/high-profile situations. The unfurling team likely did practice their unfurling regime but apparently...more
Of the wide range of challenges that compliance officers face with third parties, my favorite is: who “owns” third-party risk management? The truth is that different people within the enterprise feel different types of pain...more
Third party risk management is easily one of the most challenging risks for compliance officers. With all the attention and hype surrounding third party risk, companies have marshaled attention and resources to mitigate the...more
In response to aggressive FCPA enforcement and recurring problems with third parties, companies have spent substantial resources and time to design and implement comprehensive ethics and compliance programs. A key part of...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
The definition of “effectiveness” for a third party risk management program is quickly changing — how is your organization keeping up? I usually avoid predicting the future because you are bound to get something wrong. ...more
In this episode, I continue my exploration of internal controls around third parties in a FCPA compliance program, with Henry Mixon. ...more
The GlaxoSmithKline PLC (GSK) corruption matter in China continues to reverberate throughout the international business community, inside and outside China. The more I think about the related trial of Peter Humphrey and his...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
Today we honor one of the greatest diplomatic initiatives that occurred in my lifetime, Nixon’s trip to China; where he arrived on this date in 1972. Like most Americans I was caught completely unaware that Nixon was planning...more