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Third-Party Compliance Bribery

The Volkov Law Group

Lessons Learned from the SAP Enforcement Action — DOJ Changes Tack on FCPA Enforcement While SEC Digs into Third-Party Controls...

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A careful reading of the DOJ and SEC settlement documents for the SAP case will puzzle you.  I know I am scratching my head trying to make sense of the whole picture here.  There are a number of significant indicators of a...more

Thomas Fox - Compliance Evangelist

Holmes Debuts and How Business Ventures are Different Risks Than Third-Parties

Whether they are Joint Ventures (JVs), partnerships, franchises, team agreements, strategic alliances or one of the myriad types of business relationships a U.S. company can form outside the U.S., they present diverse risks...more

Thomas Fox - Compliance Evangelist

The Ahsani’s Information – The Fraudulently Obtained Certifications

This week I am mining the guilty pleas of the former Unaoil Chief Executive Officer (CEO), Cyrus Ahsani, and former Chief Operations Officer (COO), Saman Ahsani, for what they might mean for Foreign Corrupt Practices Act...more

Thomas Fox - Compliance Evangelist

The Panalpina Settlement Day Record May Finally Be Broken: The Unaoil Execs Guilty Pleas

Nine years ago today, on November 4, 2010, was Panalpina Settlement Day which made history for the single largest number of companies to simultaneously settle Foreign Corrupt Practices Act (FCPA)-related violations. It was...more

Burr & Forman

Walmart FCPA Settlement Shines Light On Corporate Compliance Programs

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June 20, 2019 – Walmart (NYSE: WMT) and its subsidiary, WMT Brasilia, agreed to a combined criminal penalty and disgorgement of $282M, together with WMT’s criminal guilty plea and undertakings in an NPA, to reach a global...more

Thomas Fox - Compliance Evangelist

Corruption in China: Part 2 – The Bribery Schemes

After a sidetrack into the ethical train wreck detailed by the SEC Cease and Desist Order re: KPMG yesterday, I am returning to the blog post series I am running based upon the New York Times (NYT) reporting by Alexandra...more

Thomas Fox - Compliance Evangelist

Chaucer, the Canterbury Tales and Shell Companies

According to Samuel Rubenfeld, reporting in the Wall Street Journal (WSJ) Risk & Compliance Journal, “Treasury Secretary Steven Mnuchin told lawmakers that he wants to make corporate ownership information available to law...more

The Volkov Law Group

When Diligence is Not Given its “Due”

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I find myself quibbling with compliance terms – hyper focus on small issues is not a positive trait. I often urge clients and colleagues to focus on issue of more significance and leave the smaller ones for another day....more

McDermott Will & Emery

Focus on China - October 2015

McDermott Will & Emery on

Welcome to the third issue of Focus on China Compliance for 2015. According to the FCPA Blog’s October 2015 Corporate Investigations List, China leads the countries reported to be involved in FCPA investigations with 29...more

Thomas Fox - Compliance Evangelist

Great Structures Week V – The Tacoma Narrow Bridge Failure and Preventing Failure in Your Compliance Program

I conclude my Great Structures Week with a focus on structural engineering failures: suspension bridges and the challenges of wind in their construction and maintenance. I am drawing these posts from The Great Courses...more

Dorsey & Whitney LLP

Anti-Bribery and Corruption Compliance Practices

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Compliance Week published its 2014 Anti-Bribery and Corruption Benchmarking Report, a survey of over 180 executives involved in ethics and FCPA compliance and internal audit. The Survey focused on risk, dealing with third...more

The Volkov Law Group

Mitigating Bribery Risks With Financial Controls

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Anti-corruption compliance is not as hard as it looks. In fact, by taking a step back, compliance professionals can gain insights. At the direction of compliance professionals, companies like to develop and adopt...more

NAVEX

A Prescriptive Guide To Third Party Risk Management

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The recent examples of compliance program credits for Morgan Stanley and Ralph Lauren have demonstrated that, more than ever, an effective compliance program can protect a company from criminal indictment and generate bottom...more

NAVEX

Lessons from Ralph Lauren: Designing Better Ways to Manage Third Party Risk

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Trying to avoid the unusually strict import controls in Argentina and facilitate faster clearance of its products through customs, a subsidiary of Ralph Lauren Corp. was found to have bribed local officials between 2005 and...more

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