Training The Foreign Corrupt Practices Act

News & Analysis as of

When Designing Your Compliance Training Program, Consider When NOT to Train

Have you considered the topics that you’re NOT going to train your employees on this year? It’s easy to think of all the topics you know you want to cover – or are legally required to cover; the reasons for these courses,...more

FLIR FCPA Action Highlights: Continued Focus on Penalizing Improper Expenditures for Government Officials

FLIR Systems, Inc. (“FLIR”), a publicly traded company based in Oregon, agreed to pay approximately $9.5 million to settle allegations of violations of the Foreign Corrupt Practices Act (“FCPA”) on April 8, 2015. The U.S....more

Making the Case for Compliance Training for Third Parties

How to make the case for implementing third party compliance training in your organization. A recent article in the San Francisco Chronicle profiled Jay Jorgensen, the new Global Chief of Compliance at Walmart. The...more

December FCPA Enforcement Digest – Let’s Celebrate the New Year with Anti-Bribery Training!

Happy New Year! I hope everyone had a wonderful holiday and a great start to the New Year. With that said, I hope you’re not suffering from the holiday hangover (and I don’t mean the alcohol-induced kind.) After taking...more

Germany in the World Cup and the Alstom FCPA Enforcement Action – Part II

“It was important that we played our game for 90 minutes.” That line was found in a The Daily Telegraph article entitled “The unthinkable scoreline: Brazil 1, Germany 7” by Jeremy Wilson. It was a quote from Mats Hummels,...more

Five Quick and Easy Ways To Sabotage Your Compliance Training

Ed. Note-today we have a guest post from noted ethics and compliance expert, as well as steel guitar player, Chris Bauer. Okay, you know that you need to have effective compliance training but do you really know what...more

Anti-Bribery Training from Coca-Cola: What I Learned About Bribery, Corruption and Responsibly Entering Underdeveloped Markets

A few weeks ago, I had the pleasure of attending the 22nd Annual Ethics and Compliance Conference, hosted by the ECOA. I’m always intrigued by how the topics of a conference tie together; for example, one of the speakers on...more

DOJ's 10-Point Compliance Framework

On October 1, 2014, Leslie R. Caldwell, Assistant Attorney General for the Criminal Division at the U.S. Department of Justice ("DoJ"), provided clear guidance about DoJ's expectations regarding corporate compliance programs....more

FCPA Compliance and Ethics Report-Episode 96-interview with Karen Schuder on the teaching of business ethics [Video]

In this episode I interview doctoral candidate Karen Schuder on her research into the teaching of business ethics. ...more

Creation of Yosemite and Putting Compliance at the Center of Strategy

On this day in 1890, an act of Congress created Yosemite National Park, home of such natural wonders as Half Dome and the giant sequoia trees. Environmental trailblazer John Muir (1838-1914) and his colleagues campaigned for...more

Does Your Company’s “Inadequate Compliance Program” Violate Securities Laws?

In a recent matter before the SEC, settlement of an FCPA claim with Smith & Wesson has raised some worrisome new issues for compliance officers. This settlement is noteworthy for two reasons: 1. Small and mid-sized...more

Justin Bieber Does It Again – Time For Anti Bribery Training To Save The Day

Tsk tsk tsk. Just when I thought I was only going to mention him in one blog post this year, I now have the opportunity to write another. Someone has to do it! Justin Bieber is back in the spotlight and this time it isn’t...more

Waking Up to Massive Third Party Risk Exposure: Critical Issues To Address

A little over a year ago the Rana Plaza factory collapsed and 1,100 garment workers died. This human disaster resulting from questionable construction practices and workplace safety issues focused the eyes of the world on the...more

Building an Anti Corruption Compliance Program Practical Steps 2 18 14, 9 02 AM [Video]

Companies face many risks in the anti-corruption enforcement arena. With the growing globalization of anti-corruption enforcement, companies are responding quickly by enhancing their anti-corruption compliance...more

Bringing It All Home, the Two Tough Cookies Wrap It Up For You, Part II

This one is tough, especially in global organizations. In many countries, you simply cannot run a background check, as criminal records are not public. In others, you can run them, but the criminal offense must be related to...more

Monitoring and Auditing Your Anti Corruption Compliance Program  [Video]

Companies have designed and implemented anti-corruption compliance programs. An important element of an effective compliance program is monitoring and auditing the program to identify issues for improvement. Working in...more

FCPA Training: The Basics [Video]

This webinar provides a basic FCPA training program. A number of webinar attendees have requested that I conduct a basic FCPA webinar outlining how the FCPA statute applies to international business operations. The topics...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

Gehrig’s Streak Ends And Compliance Week 2014 Is Near

Today we celebrate greatness in two areas. The first is in baseball as on this day in 1939, “New York Yankees first baseman Lou Gehrig benches himself for poor play ending his streak of consecutive games played at 2,130....more

How to Accurately Identify the Corrupt Intent Behind Bribery: Real Life Cases, Anti-Bribery Training

As I mentioned in my last blog, FCPA expert Tom Fox was recently asked in an interview by Corporate Compliance Insights to define the criteria for what constitutes a bribe under the FCPA. He outlined three key criteria: Is...more

Shirley Temple And Excellence In FCPA Training Video

Today we honor one of the most interesting personalities of the 20th century, Shirley Temple, who died yesterday. She was probably the greatest child actress of all-time, being the lead grossing star for five straight years...more

Survey Reveals Social Media Training Top Compliance Priority

In The Network’s online survey last month, we asked you which compliance initiatives you would consider a priority in 2014. While there are many compliance issues at hand – code of conduct refresh, social media compliance,...more

Why You Must Educate Your Employees on the Meaning of “Anything of Value” (FCPA Training Series)

What constitutes a bribe under the FCPA? This question was posed to FCPA expert Tom Fox in an interview series by Corporate Compliance Insights. To echo his statements, there are three key criteria to consider: Is there...more

Why Anti-Bribery Training and Policies are Two Essentials to Fuel FCPA Compliance

FCPA compliance is a hot topic in the oil & gas industry. Unfortunately, hearing about violations in this sector isn’t all that unusual. In fact, according to The Network’s research (based on industry findings), over the past...more

Mandatory Training for Third Parties – Effective or Protective?

What is the risk? Third-party liability for contractors, resellers, agents and supply chain partners is an issue that continues to bedevil corporations who need or choose to use third parties. The headlines and DOJ/SEC...more

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