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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

FCPA Compliance and Ethics Report-Episode 64-Managing the Third Party Relationship Under the FCPA, Part II [Video]

In this episode I continue my review of the five steps of managing third parties under the FCPA. In this part II, I discuss steps 3-5....more

FCPA Compliance and Ethics Report-Episode 63-Managing the Third Party Relationship Under the FCPA, Part I [Video]

In this episode I being a two part series on how to manage your third party relationships under the FPCA and UK Bribery Act. In this episode, steps 1-the Business Justification and Step 2-the Questionnaire. ...more

The Mann Gulch Fire and How Far Down the Chain Do You Need to Go?

Robert Sallee died last week. A smoke jumper, he was the last survivor of the Mann Gulch Fire, one of the worst disasters in the history of the US Forest Service. Sallee’s story and that of the Mann Gulch Fire was detailed in...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

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

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

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

Burr Alert: Blowing The Cap Off Statutory Damages Under The FCCPA?: An Analysis Of Kahmeyer v. Federal Credit Corporation

In Kahmeyer v. Federal Credit Corporation, the 13th Judicial Circuit in Hillsborough County, Florida released an opinion that has given new life to the argument that each violation of the Florida Consumer Collection Practices...more

Don’t Spread Your Compliance Program Too Thin

“You do not want to be spread too thin”. When I heard that phrase a light bulb went off inside my head. It was uttered to me by Jan Farley, the Chief Compliance Officer (CCO) of Dresser-Rand. I asked Jan what he meant by 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

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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