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Internal Control Lessons Learned from Global Anti-Corruption Enforcement in 2024

2024 saw another strong year of Foreign Corruption Practices Act (FCPA) enforcement actions from the United States Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). There were 15 resolutions with...more

Balancing Courtesy and Compliance: Best Practices in Corporate Hospitality

Whether part of local customs, relationship building or ways to give thanks, gift giving and hospitality (collectively referred to here as “Hospitality”) is a sizable business, with the global market being estimated at USD839...more

The Extended Network: Managing Third Parties' Bribery Risks

Approximately 90% of U.S. Foreign Corrupt Practices Act (FCPA) enforcement cases from its inception in 1978 have involved third-party intermediaries engaging in bribery schemes. The reduced level of control or oversight...more

When the Stakes Are High: Managing a Crisis-Led Investigation From Incident to Remediation

1 75 An investigative journalist implicates the company. An auditor threatens to resign. Premises are raided by enforcement agencies. Not all investigations are created equal and in a recent talk given at the General Counsel...more

Proceeds of Crime and the Cautionary Tale of Convicted Fraudster Achilleas Kallakis

Recent SFO Confiscations Linked To Decade-Old Crime - On 24 November, the Serious Fraud Office (SFO) successfully confiscated £250,000 from Achilleas Kallakis, which was held as a debenture by The Queen’s Club, home of the...more

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