News & Analysis as of

Third-Party Foreign Corrupt Practices Act (FCPA) Anti-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

StoneTurn

5 Tips For Meeting DOJ’s New CCO Certification Requirements

StoneTurn on

The DOJ has signaled that CEO and CCO certifications will become a staple of all corporate settlement agreements. Critics worry CEOs and CCOs face undue personal liability and argue it will dissuade CCOs from accepting the...more

Lowenstein Sandler LLP

1st FCPA Case Under Biden Offers Compliance Reminders

Lowenstein Sandler LLP on

The first Foreign Corrupt Practices Act case under President Joe Biden's administration reinforces some well-known risks for companies subject to the FCPA — namely, increased U.S. and international enforcement and cooperation...more

American Conference Institute (ACI)

[Virtual Event] Foreign Corrupt Practices Act New York - June 2nd - 3rd, 10:00 am - 4:00 pm EDT

ACI’s New York Conference on Foreign Corrupt Practices Act is returning in a virtual format on June 2 – 3, 2021. Once again, this anti-corruption event will gather the key stakeholders: senior government officials, industry...more

Thomas Fox - Compliance Evangelist

Farewell to Lou Brock and Implementing Internal Controls

The first step is to convert your company’s compliance risks into internal control objectives. The internal control objectives are then given to each business unit with instructions to develop controls, which meet the...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

NAVEX

Classifying Your Third Parties: An Essential Third-Party Due Diligence First Step

NAVEX on

From a corruption risk perspective, companies should be looking at their third parties that act in a representative capacity. Look no further than the 2018 FCPA enforcement actions to date for examples, all of which have...more

Foley & Lardner LLP

Anti-Bribery Compliance Meets Permits, Approvals and Licences in India

Foley & Lardner LLP on

Obtaining permissions, approvals and licences in India creates high risks for bribery on account of there being significant interaction between the company and government authorities. Originally published by IBA...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

Pillsbury Winthrop Shaw Pittman LLP

China Aims to Strengthen Regulations on Commercial Bribery

Recently, the Legal Affairs Office of the State Council released draft amendments (Draft Amendments) to the Anti-Unfair Competition Law (AUCL) of the People’s Republic of China (PRC) for public comments. The Draft Amendments...more

Foley & Lardner LLP

Common FCPA Issues

Foley & Lardner LLP on

As our previous posts illustrate, violations of the Foreign Corrupt Practices Act (“FCPA”) can carry a hefty cost. Two issues are commonly the impetus for FCPA violations and, practically speaking, pose significant FCPA...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

Thomas Fox - Compliance Evangelist

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

Thomas Fox - Compliance Evangelist

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

Thomas Fox - Compliance Evangelist

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

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