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

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

Global Investigations: Reading The Signals

As the global economy recovers, how will regulators respond? Experts provide perspectives on trends in regulatory and corporate investigations. Global trends in regulation - In the wake of the financial crisis,...more

China Bribery Crackdown Underscores the Need for Stronger Compliance Programs and Risk Assessments

Recently, the Chinese government reported that GlaxoSmithKline (GSK) would agree to pay almost $500 million in fines to settle allegations of bribery, and that some former GSK employees would receive prison sentences. While...more

Internal Controls for Third Party Representatives in a FCPA Compliance Program

This week, I am continuing my podcast series, on the FCPA Compliance and Ethics Report, on internal controls in best practices anti-corruption compliance program, under the Foreign Corrupt Practices (FCPA), UK Bribery Act or...more

Risk Assessments - the Cornerstone of Your Compliance Program, Part III

Today, I conclude a three-part series on risk assessments in your Foreign Corrupt Practices Act (FCPA) or UK Bribery Act anti-corruption compliance program. I previously reviewed some of the risks that you need to assess and...more

A solid business strategy as the foundation of Anti-Bribery Compliance

Ethical Boardroom was kind enough to ask me to share my thoughts on what management techniques exist for promoting a cost effective FCPA or UK Anti-Bribery program across a global organisation. Clearly, there is no shortage...more

Does Your Company Still Allow Facilitation Payments?

One of the more confusing areas of the US Foreign Corrupt Practices Act (FCPA) is in that of facilitation payments. Facilitation payments are small bribes but make no mistake about it, they are bribes....more

Continuous Improvement Of Your Compliance Program, Part II

Anti-corruption, anti-bribery, anti-money laundering (AML) programs policies and procedures and even export control systems are seemingly in a constant state of evolution. Many companies are struggling with the challenge of...more

Corruption Risks in Pharma Manufacturing in Russia

The Russian government has targeted the pharmaceutical industry for growth and development, adopting a program Pharma 2020 Strategy. This program aims to improve the competitiveness of the Russian pharmaceutical industry and...more

The UK Bribery Act, Three Years On: Can We Relax Yet?

The Bribery Act 2010 has now been in force for three years. Despite the announcements and commentary that it heralded a new and aggressive face toward corporate corruption, there have as yet been no corporate prosecutions...more

Survey: Anti-Corruption Laws Have Major Impact on Corporate Compliance Policies

With over $1.5 billion in fines assessed by the U.S. Securities and Exchange Commission for violations of the Foreign Corrupt Practices Act (FCPA) since 2010, corruption concerns are playing a larger role in corporate...more

FCPA Compliance and Ethics Report-Episode 63-Managing the Third Party Relationship Under the FCPA, Part I [Video]

In this episode I being a two part series on how to manage your third party relationships under the FPCA and UK Bribery Act. In this episode, steps 1-the Business Justification and Step 2-the Questionnaire. ...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

So You Want to See Messi, Neymar, Ronaldo, and Xavi: Brazil Issues Directive Barring Government Officials From Receiving World Cup...

Earlier today, the Office of the Comptroller General in Brazil, Controladoria-Geral da União (“CGU”), issued a sweeping directive barring government officials from accepting offers to attend or participate in the upcoming...more

Life Cycle Management Of Third Parties – Step 5 – Management Of The Relationship

Today ends my review of what I believe to be the five steps in the management of a third party under an anti-bribery regime such as the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act. On Monday, I reviewed Step 1 –...more

Life Cycle Of Third Party Management – Step 2 Questionnaire

Today, I continue my five-part series on the life cycle of third party management under an anti-bribery/anti-corruption regime such the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act, reviewing Step 2, which I label...more

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