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Jones Day

Japan Legal Update Vol. 53 | Autumn 2020

Jones Day on

Technology - Japan Ministries Support Expansion of E-Signature Use - On September 4, 2020, the Japanese Ministry of Internal Affairs and Communications, the Ministry of Justice, and the Ministry of Economy, Trade and...more

Thomas Fox - Compliance Evangelist

Bribery Schemes from 2019 FCPA Enforcement Actions

In today’s blog post, I want to look at some of the more unusual bribery schemes from Foreign Corrupt Practices Act (FCPA) enforcement actions in 2019. Some of these schemes were not unusual but they were accomplished with...more

Thomas Fox - Compliance Evangelist

Quad/Graphics – The Sham-ness of It All

This week I will be considering the recent spate of Foreign Corrupt Practices Act (FCPA) enforcement actions brought by the Securities and Exchange Commission (SEC) at the close of its fiscal year. Last week saw several...more

Thomas Fox - Compliance Evangelist

The Dutch Tulip Bubble and Internal Controls for Third Parties

Internal controls are a key tool to operationalize your third-party risk management program. The basic internal controls, that should be a part of any financial controls system. There were four significant controls the...more

The Volkov Law Group

Addressing AML Risks in Your Third-Party and Vendor/Supplier Relationships (Part II of III)

The Volkov Law Group on

Global companies should incorporate AML risks into their risk analysis of their third-party distributors, agents and other intermediaries. The basic questionnaire, due diligence risk analysis, contractual provisions,...more

Thomas Fox - Compliance Evangelist

Enforcement Week III: Johnson Controls FCPA Enforcement Action – Part 2

I continue my review of the Johnson Controls, Inc. (JCI) Foreign Corrupt Practices Act (FCPA) enforcement action today by focusing on the Department of Justice’s (DOJ’s) Declination to Prosecute. Yesterday, I considered the...more

The Volkov Law Group

Johnson Controls Pays $14 Million for China FCPA Violations: DOJ Declines Prosecution

The Volkov Law Group on

At first glance, the SEC’s recent enforcement action against Johnson Controls for $14 million for FCPA violations in China, along with a Justice Department declination under its new Pilot Program, appears to be a “routine”...more

Thomas Fox - Compliance Evangelist

Enforcement Week II: The Johnson Controls FCPA Enforcement Action – Part I

I continue my exploration of recent enforcement matters and issues by turning to the Johnson Controls, Inc. (JCI) Foreign Corrupt Practices Act (FCPA) enforcement action, which was announced last week. Mike Volkov has called...more

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