News & Analysis as of

Third-Party Compliance Corruption

NAVEX

What a New SEC Enforcement Sweep Is Really Telling Us

NAVEX on

Attention all compliance officers at large technology companies – have you checked your mail lately? Because you might find a letter from the Securities and Exchange Commission with FCPA risk written all over it....more

Paul Hastings LLP

Latest DOJ Guidance and Non-US Companies: What to Expect and How to Handle it

Paul Hastings LLP on

Since his election, President Joe Biden has loudly reaffirmed U.S. ambitions in the fight against global corruption, domestically and abroad. Thus, in June 2021 the “Biden memorandum” declared the fight against...more

The Volkov Law Group

Addressing Beneficial Ownership Requirements in Your Compliance Program (Part I of IV)

The Volkov Law Group on

We repeatedly hear about the importance of beneficial ownership, and the requirement that companies confirm beneficial ownership of its third-parties, vendors and suppliers.  At the same time, there is increasing pressure...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

Thomas Fox - Compliance Evangelist

AI in Compliance – Strategies For and With AI

Last week, I penned a blog series around a special White-Collar Crime section in the July Harvard Business Review (HBR). This week, I propose to write a multipart blog post series based upon the MIT Sloan Management Review...more

Burr & Forman

Walmart FCPA Settlement Shines Light On Corporate Compliance Programs

Burr & Forman on

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

The Volkov Law Group

DOJ’s New Corporate Compliance Guidance: Training and Communications, Reporting and Investigations, Third-Party Management and...

The Volkov Law Group on

The Justice Department’s new Corporate Compliance Guidance is keyed to the concept of a “well-designed compliance program.” Under this concept, we first examined risk assessments and policies and procedures. ...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

Robins Kaplan LLP

Insight from the DOJ Fraud Section

Robins Kaplan LLP on

Without fanfare, on February 8 the Fraud Section of the Department of Justice (DOJ) published new corporate compliance guidance on its public website. The guidance is presented as a set of topics and questions, entitled...more

The Volkov Law Group

When Diligence is Not Given its “Due”

The Volkov Law Group on

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

NAVEX

New Year, New Focus on Enforcement: The U.K. Strengthens Anti-Bribery and Corruption Enforcement

NAVEX on

U.K. regulators have started 2015 with a bang, promising increased cooperation among regulatory agencies, and tougher enforcement of financial crimes, with an emphasis on anti-bribery and corruption efforts....more

The Volkov Law Group

Managing And Minimizing Your Third-Party Risks

The Volkov Law Group on

Let’s start with a few basic assumptions – we all know that third parties are often the most significant risk for corruption. ...more

Thomas Fox - Compliance Evangelist

Analyzing the Risk of Distributors Under the FCPA-the Simon Approach

Ed. Note-we continue our series on the risk analysis and assessment of distributors under the FCPA and management of that risk. Today, David Simon contributes a guest post where he articulates another approach to the risk...more

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