Corporate Use of Third-Party Artificial Intelligence (AI) Tools
One Month to More Effective Written Standards: Day 17 – Policies for Third-Parties
Third Party Observation in Patent Prosecution in China
Consumer Finance Monitor Podcast Episode: Recent Federal and State Debt Collection Developments
Thobekile Cynthia Khumalo on Third Party Due Diligence
Protecting Trade Secrets When Facing Lawsuits or Alternative Dispute Resolution Procedures
Education Data Privacy and Security Laws: Best Practices for School Districts
Episode 162 -- Jessica Sanderson on How to Conduct a Remote Third Party Audit
VIDEO: Update on Third Party Workers’ Compensation Settlements in Pennsylvania
Episode 120: Interview of NAVEX Global Third-Party Risk Officials: Chris Bailey and Stephen Gooding
Subro Sense Podcast - Unpacking Product Claims Against Amazon
Business Succession Planning: Strategies for the Transition
E17: Carpenter Decision Builds Up Privacy from #SCOTUS
Day 17 of One Month to More Effective Continuous Improvement-Financial Health Monitoring
Day 6 of One Month to More Effective Continuous Improvement-Data Analytics and the Monitoring of Third Parties
FCPA COMPLIANCE REPORT-EPISODE 337, JAMES GELLERT ON ASSESSING 3RD PARTY FINANCIAL HEALTH FOR COMPLIANCE
FCPA Compliance Report-Episode 274, Scott Lane on an holistic approach to third party management
FCPA Compliance and Ethics Report-Episode 169-the First Mailbag Issue
FCPA Compliance and Ethics Report-Episode 95-interview with Scott Killingsworth on Private to Private Compliance Solutions
FCPA Compliance and Ethics Report-Episode 88, Internal Controls for Third Parties Under the FCPA, Part I
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
Numerous laws (U.K. Bribery Act guidance document, German Supply Chain Act, Foreign Corrupt Practices Act resource guide, OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and...more
As I always say, the factual underpinnings of every FCPA enforcement action provides important insights into bribery schemes. At the core of every scheme is the misappropriation of money from the company coffers for improper...more
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
On February 17, 2022, KT Corporation (KT, formerly known as Korea Telecom) resolved a Foreign Corrupt Practices Act (FCPA) enforcement action with the Securities and Exchange Commission (SEC) related to corruption schemes in...more
Key considerations around bribery and corruption risks, as the mining & metals sector is gaining critical momentum in the world's energy transition toward a low-carbon future. Mining & metals in a low-carbon world - The...more
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
Last week, Airbus SE (Airbus) settled a long-standing corruption scandal by agreeing to enforcement actions in three countries; France, the United Kingdom and the US. The matter involved a massive, worldwide, long running...more
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
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
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
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
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
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 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
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
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
If you review the last ten years of FCPA enforcement, the unmistakable pattern is rising expectations with regard to corporate compliance programs, particularly with regard to third party due diligence and risk management....more
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
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
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
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
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Let’s start with a few basic assumptions – we all know that third parties are often the most significant risk for corruption. ...more
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