UK Bribery Act Chief Compliance Officers

The UK Bribery Act is an act of the Parliament of the United Kingdom enacted in 2010 to prevent, combat and penalize acts of bribery. The Bribery Act creates four offenses: 1) bribing another person 2) being... more +
The UK Bribery Act is an act of the Parliament of the United Kingdom enacted in 2010 to prevent, combat and penalize acts of bribery. The Bribery Act creates four offenses: 1) bribing another person 2) being bribed 3) bribing a foreign official 4) failure of a corporation to prevent bribery on its behalf. The Act provides for very stringent penalties and is considered one of the toughest pieces of anti-bribery legislation in the world.  less -
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For FCPA Compliance, Tone At The Top Key, Lack of Policies A Difficulty

The number of FCPA enforcement actions brought in recent years has declined. The SEC, for example, reports that in fiscal 2013 it brought 8 cases, compared to 10 in 2012 and 15 in 2011. Nevertheless, those who might be...more

Naval Theorists And The Measurement Of Compliance

If are interested in naval history, strategy and tactics, I have a question for you: Are you a disciple of Alfred Mahan or Julian Corbett? If you are a Mahanian, you probably focus on large naval engagements or the great...more

Ignoring The Obvious: Facilitation Payments

Chief Compliance Officers have plenty of issues to focus on when it comes to anti-corruption compliance. If you rank the risks, facilitation payments are not at the top of the list, especially if you have sales staff and...more

Facilitation Payments: An Intractable Problem?

It sounds easy on paper. A company announces that it has banned all facilitation payments. It is a worthy goal. It sounds admirable. The FCPA permits facilitation payments. The UK Bribery Act prohibits facilitation...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

How to Reach Your Audience in Compliance Training – The Use of Charisma

One often hears or reads about complaints that compliance training is dull, nay even boring. I mean, how many times can you expect someone to be lectured to on the riveting subject of the Foreign Corrupt Practices Act (FCPA)...more

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