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Training The Foreign Corrupt Practices Act Risk Assessment

Department of Justice Fraud Section Provides Guidance on Evaluating Corporate Compliance Programs

by Jones Day on

On February 8, 2017, the United States Department of Justice ("DOJ") Fraud Section published a blueprint for assessing corporate compliance efforts, titled "Evaluation of Corporate Compliance Programs" ("Guidance"). It...more

New Guidance from the DOJ on Your Compliance Program

by NAVEX Global on

The U.S. Department of Justice (DOJ), Criminal Division, Fraud Section, recently released new guidance associated with its Guide to the U.S. Foreign Corrupt Practices Act. The guidance, entitled Evaluation of Corporate...more

Code of Conduct Training – Now What?

by Michael Volkov on

When it comes to corporate compliance programs, change does not occur quickly. CCOs are extremely pleased with their improved delivery of code of conduct training. Across the board, companies are refining their codes of...more

Make Sure You Address Compliance with Export Controls

by Michael Volkov on

Compliance officers have to avoid professional myopia. The focus of compliance these days has been on anti-corruption, antitrust, and AML, depending on your company’s industry. They fit nicely together under an...more

Compliance Lessons from the Olympus Corporate Integrity Agreement – Part II

by Thomas Fox on

Sir George Martin died yesterday. For anyone born after the break up of the Beatles, this name is probably not too familiar. However, even more than Brian Epstein, the band’s first professional manager, Martin truly was the...more

What the Government Expects to Find in an Anti-Corruption Compliance Program

by Dentons on

Similar to Foreign Corrupt Practices Act enforcement generally, the federal government has expanded what it expects to find in an anti-corruption compliance program. U.S.-connected companies operating internationally...more

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

by Thomas Fox on

“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

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

by NAVEX Global on

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

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

by NAVEX Global on

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

by Michael Volkov on

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

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

by Thomas Fox on

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

A Prescriptive Guide To Third Party Risk Management

by NAVEX Global on

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

Return To The Baker’s Dozen In A Best Practices Compliance Program – Total Part II

by Thomas Fox on

Yesterday I reviewed the facts surround Total SA’s (Total) lengthy bribery scheme to win contracts in Iran....more

Socio-Economic and Cultural Risk Factors That Drive Corruption: A Focus on the ‘Supply Side’ of the Equation

by Thomas Fox on

This is the last installment of my three party series regarding Occupational Fraud. One can never lose focus on what I consider the key question as they enter or play within the international arena: What are the...more

Establishing an Effective Compliance Program: An Overview to Protecting Your Organization

by Holland & Knight LLP on

In This Issue: - Overview - Standards and Procedures - Organizational Leadership and Culture - Reasonable Efforts to Exclude Bad Actors From Managerial Ranks - Training and Education - Monitoring,...more

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

by Thomas Fox on

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

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