News & Analysis as of

Anti-Bribery and Corruption Compliance Practices

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

Tackling the realities of due diligence in a global setting

The Resource Guide to US FCPA* (the Guidance) promulgated by the DOJ and SEC emphasizes the need for appropriate due diligence and vetting before engaging third parties. The Guidance details the need to conduct...more

Risk-based due diligence of third-party intermediaries: a scorecard approach

Companies operating internationally often engage numerous – sometimes even thousands – of third parties around the world to help facilitate their business. Alongside the growth of such relationships, the risks posed by them...more

Third Party Risk in a Global Environment

Most organizations engage with hundreds, if not often thousands, of third party vendors, suppliers, agents and business partners, creating a daunting and ever-expanding scope of risk. This risk arises from: 1....more

Bribery, Corruption, and Third Party Risks - What Can You Do.

Please see full Infographic below for more information....more

A Prescriptive Guide To Third Party Risk Management

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

Drilling Down On Due Diligence: Raising The Bar

I am sure Justice Department and Securities and Exchange Commission lawyers sometimes sit back and marvel at the world they have helped create – Companies are devoting more resources to the due diligence process for screening...more

Companies Turning to Technology to Combat Third Party Risk

As technology continues to increase the efficiency of most operational tasks, it should come as little surprise that technology can now improve the labor-intensive process of managing third party risk. The days of manual...more

Managing And Minimizing Your Third-Party Risks

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

The Smaller The 401(k) Plan, The Bigger The Problems

401(k) plans are a world of contradictions. It’s one of the few employer provided benefits that an employee usually pays for through their account balance. It’s a retirement plan that an employer offers that the employee has...more

Why Ignorance Isn’t Bliss When It Comes to Third Party Risk Management

In a recent webinar, Randy Stephens, VP of our Ethical Leadership Group, and Mike Vermilion, Senior Director of Third Party Risk Solutions, outlined a best practice approach to risk-adjusted due diligence for third party...more

Kroll And Compliance Week Survey Anti-Bribery And Anti-Corruption

Not many people realize that the US has elected one president who served as a prisoner of war....more

From The Compact Model To The Luxury Model – Managing Your Third Party Risk

I am currently attending the Hanson Wade Oil and Gas Supply Chain Compliance conference in Houston. The event is excellent and the presentations have been ‘spot on’ for the nuts and bolts of how to do compliance. As the...more

Anti-Corruption High-Risk Audits

The Justice Department and the SEC should be credited with promoting new compliance strategies and best practices. Whatever you may think about the DOJ/SEC FCPA enforcement program, they have pushed businesses to enhance...more

Third Party Risks And Internal Auditors

You remember the corny song – “People who need people are the luckiest people in the world.” For a Chief Compliance Officer that saying is particularly important when it comes to third party risks. CCOs need their...more

Due Diligence When Renewing A Third Party Relationship

Happily married couples like to renew their wedding vows. It is a great celebration of love. When you meet the spouse of your dreams, it is a wonderful ceremony. I look forward to such an event with my wonderful wife,...more

ACADEMI's Suzanne Rich Folsom and PwC's Glenn Ware on Moral Hazard [Video]

Suzanne Rich Folsom, Senior Vice Presidence, Chief Regulatory and Compliance Officer, and Deputy Genreal Counsel for Academi LLC and Glenn Ware, a Principal at PwC discuss the ways in which on Moral Hazard emerges in the...more

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

Distributors Should Be Analyzed As Any Other Third Party Representative in the Sales Chain

Ed. Note-David Simon is a partner at Foley and Lardner and Bill Athanas is a partner at Waller Lansden Dortch & Davis, LLP. Both have practices which include FCPA compliance. After my recent post on distributors under the...more

Antimonopoly Law Considerations and Risk Management in connection with M&A Transactions

In This Presentation: - General Indemnity: (1) Background and structure (2) Main provisions (3) Conduct of claims - Antitrust Indemnity: (1) Background (2) Main provisions (3) Conduct of...more

The FCPA Guidance on the Ten Hallmarks of an Effective Compliance Program

Many commentators are still mining the Department of Justice (DOJ)/Securities and Exchange Commission (SEC) publication, A Resource Guide to the U.S. Foreign Corrupt Practices Act, (the “Guidance”), which was released last...more

The Lilly FCPA Enforcement Action (Part III) Lessons Learned from Russia

This Part III is the final installment of my review of the Eli Lilly and Company (Lilly) FCPA enforcement action brought by the Securities and Exchange Commission (SEC). In this Part III, I will review the FCPA issues that...more

From China to Poland and Brazi l- The Lilly FCPA Enforcement Action- Part II

In Parts II and III of my review of the Eli Lilly and Company (Lilly) Foreign Corrupt Practices Act (FCPA) enforcement action brought by the Securities and Exchange Commission (SEC), I will discuss some the processes and...more

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