UK Bribery Act Compliance

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 -
News & Analysis as of

How to Conduct Internal Investigations Outside the United States

Think of a U.S.-headquartered multinational when it receives an allegation of serious misconduct at one of its overseas operations. Maybe the company whistleblower hotline just got a tip that a secretary in the Buenos Aires...more

Navigating FCPA Risks in Global Private Equity Ventures

In light of the global nature of the private equity industry, minimizing Foreign Corrupt Practices Act (FCPA) risks is an important consideration for private equity firms and their portfolio companies. ...more

Supply Chain as a Source of Compliance Innovation

On this day we celebrate the greatest upset in the history of the NCAA Basketball Tournament, when Villanova beat Georgetown for the 1985 national championship. Georgetown was the defending national champion and had beaten...more

The Future of U.K. Enforcement of Financial Crimes: Four Clues for 2015

The legal and compliance landscape is changing quickly—it’s up to organisations that do business in the U.K. to strengthen their compliance programmes to meet these new challenges. In this whitepaper, Andrew Foose, vice...more

Bribery and Compliance in India: Know the Challenge and Prepare for It

Today I welcome Sherbir Panag, for another post in my series of country discussions, where we will address Bribery and Anti-Bribery Compliance in India. As a forward, this was an interesting engagement, as it provided me...more

What you (still) may not know about the UK Bribery Act

While many companies have implemented policies and procedures in response to the Foreign Corrupt Practices Act, as amended ("FCPA") that combat bribery by the organization, its employees and agents, many companies have not...more

Assessing Internal Compliance Controls – Part II

In this blog post I continue my exploration of how you should assess your compliance internal controls using the Committee of Sponsoring Organization of the Treadway Organization (COSO), publication “Internal Controls –...more

Gary Owens, Laugh-In and Accountability in Your Compliance Program

If you were alive at all during the 1960s, you will recall that one of the cultural phenomenon’s was NBC’s television show Laugh-In. It was brought to you from the NBC studios in beautiful downtown Burbank and featured one...more

January FCPA Enforcement Digest – FCPA Compliance Training Top Priority in 2015

With as much FCPA activity as we saw in December, I thought our January news digest might take on a different flavor. I was wrong – January brought a slew of new FCPA-related stories. ...more

Just Say No, the Power of No and Compliance

What is the first thing that you think of about Former First Lady Nancy Reagan? Right up there for me is three things actually Just Say No, which was her campaign against not only drug abuse but also premarital sex in the...more

Language Solutions as Preventative Tool in Anti-Corruption Compliance

Ed. Note-I partnered with Merrill-Brink to write a White Paper on the use of local languages as a preventative tool in FCPA, UK Bribery Act and anti-corruption compliance. Today’s blog post is an excerpt from the full article...more

Marx Brothers Compliance Week Continues – The Stateroom Scene and High-Risk

I continue my exploration of the Marx Brothers’ movies by looking at the famous Stateroom scene from the MGM release A Night at the Opera. In researching this I was somewhat stunned to find that the scene was written and...more

What’s the Password for Compliance? Swordfish and Lessons for the CCO

I continue my exploration of the Marx Brothers this week by looking at their most successful commercial film made for Paramount, Horse Feathers. While Duck Soup is and always will be my favorite film due to its overall and...more

Get Your Tootsie-Frootsie Ice Cream; Hiring as Part of Your Compliance Program

One of my great loves is the Marx Brothers. I fell in love with their rapid-fire wiseacre remarks as a teenager and have been enthralled with them since then. I have seen all of their movies, most of their television...more

FCPA Predictions for 2015 (Part II of II)

The key to being a successful (FCPA) prognosticator is never to keep score. If you do, you are likely to be disappointed. Instead, I follow the strategy of calculated distraction – for example, I predicted last year...more

Hiring and Promotion in Compliance – Wait for Great

The role of Human Resources (HR) in anti-corruption programs, based upon the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act, is often underestimated. I come from a HR background and practiced labor law early in my...more

Building Your Third Party Due Diligence Checklist: The Right Pieces, Processes and Presumptions

A comprehensive approach to third party and vendor due diligence management is essential for any company conducting business globally. A strong due diligence program’s purpose is two-fold...more

International News: Focus on Compliance

In This Issue - Welcome to the final issue of International News for 2014. As regulatory oversight of companies—from Sarbanes Oxley and the Dodd-Frank Act to the Foreign Corrupt Practices Act and the UK Bribery...more

Sherlock Holmes and Innovation in the Compliance Function, Part I – A Study In Scarlet

Today begins a week of double themed blog-posts. First I am back with an homage to Sherlock Holmes, for it was in the magazine Beeton’s Christmas Annual that the characters Sherlock Holmes and Watson were introduced to the...more

Doing Business in India – Corruption Risks and Responses

Recently the US law firm of Foley and Lardner LLP and MZM Legal, Advocates & Legal Consultants in India jointly released a white paper, entitled “Anti-Bribery and Foreign Corrupt Practices Act Compliance Guide for U.S....more

Shoring Up Your Internal Controls to Keep Your FCPA Compliance Program Current

We recently hosted a webinar featuring noted FCPA expert Tom Fox. Tom explained exactly what the DOJ and SEC look for when enforcing the FCPA and how organizations can stay within the FCPA regulations. Jimmy Lin, our VP of...more

How to Avoid a Mousetrap – Resource Reductions in Your Compliance Function

On this day, 62 years ago, “The Mousetrap”, a murder-mystery written by Agatha Christie, opened at the Ambassadors Theatre in London. The crowd-pleasing whodunit has become the longest continuously running play in history,...more

The Strategic Use of Compliance

What is your company’s compliance strategy? By this I do not mean what is your company doing to put in a place a best practices anti-corruption compliance program that meets the requirement of the Foreign Corrupt Practices...more

FCPA Compliance and Ethics Report-Episode 108-Supply Chain Under the FCPA [Video]

In this episode I discuss several different risk based models to evaluate your supply chain under the FCPA or UK Bribery Act. ...more

Leading Pharmaceutical Company Fined $491 Million for Bribery

A Chinese court convicted a large British pharmaceutical company of corruption and bribery while doing business in China. As a result, the company must pay a record-breaking fine of $491 million while each of the implicated...more

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