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Anti-Bribery The Foreign Corrupt Practices Act Risk Assessment

DOJ Issues New FCPA Policy Offering Incentives to Encourage Disclosure of Foreign Bribery and Corruption Misconduct

by Foley & Lardner LLP on

On November 29, 2017, Deputy Attorney General Rod Rosenstein announced that the U.S. Department of Justice (DOJ) was issuing a new enforcement policy covering its enforcement of the Foreign Corrupt Practices Act (FCPA). The...more

ISO 37001: Answers to the 5 Questions We’ve Heard Most About the Standard

by NAVEX Global on

It’s been a month since ISO 37001 was published and there are some questions we have heard percolating in the compliance world about what this means. These are the questions we’ve been hearing the most...more

A New Tool for Anti-Bribery Compliance Program: ISO 37001

Recently, the International Organization for Standardization (ISO) adopted a new set of standards, designated as ISO 37001, to assist organizations in their ongoing fight against bribery. As a result of recent increases in...more

Tribute to Star Trek and Anti-Corruption Compliance Programs

by Thomas Fox on

September 8th is the 50th anniversary of the premier episode of the most iconic science fiction related television show during my lifetime – Star Trek. As most of you know, I am a self-confessed uber-trekkie and I can still...more

Hallmark 4- Risk Assessments

by Thomas Fox on

One cannot really say enough about risk assessments in the context of anti-corruption programs. Since at least 1999 the DOJ has said that risk assessments that measure the likelihood and severity of possible Foreign Corrupt...more

2016 Trends #8: Getting Serious About Anti-Bribery & Corruption Efforts and Third-Party Risk Management

by NAVEX Global on

By now, most organizations understand the importance of identifying and addressing any exposure they have to violations of anti-corruption and bribery (ABC) laws. Much attention has been given to recent cases, and to...more

Star Wars Week Part I – How do You Evaluate a Risk Assessment?

by Thomas Fox on

Today I begin a series of Star Wars themed blog posts to celebrate the upcoming release of the next entry in the Star Wars franchise, Episode VII – The Force Awakens. Please note that I will only use the first three movies,...more

Australian Anti-Bribery & Compliance Trends

Today we welcome Ted Williams, Partner, Piper Alderman. Ted, can you share some of your background and experience? TW: Thank you, Richard, for the opportunity to engage with your community, and it was a pleasure to...more

Layla and Other Love Songs and Risk Assessments

by Thomas Fox on

On this date in October 1971, Duane Allman died. He was the co-founder, along with his brother Greg, of the Allman Brothers Band. For my money he was one of the greatest guitarists of all time. At the time of his death, the...more

The High Cost of an FCPA Violation

by Foley & Lardner LLP on

Violations of the Foreign Corrupt Practices Act (“FCPA”) can lead to hefty penalties. Indeed, individuals who violate the FCPA, and their employers, could be on the hook for a variety of penalties described below. Companies...more

Risk-based due diligence of third-party intermediaries: a scorecard approach

by DLA Piper on

Companies operating internationally often engage numerous – sometimes even thousands – of third parties around the world to help facilitate their business. Alongside the growth of such relationships, the risks posed by them...more

The Danger Of A “Paper” Compliance Program

by Michael Volkov on

The FCPA Guidance contains many important compliance reminders which should be incorporated into every anti-corruption compliance program. Perhaps the most important observation included in the FCPA Guidance was the...more

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