News & Analysis as of

Bribery Compliance

DOJ – Aggressive International Anti-Corruption Enforcement to Continue

by Thomas Fox on

Acting Assistant Attorney General Ken Blanco spoke yesterday at FCPA/OECD Anniversary Conference at the NYU School of Law. His remarks made clear not only the importance of enforcement of laws against bribery and corruption...more

Rolls Royce in America – Four Guilty Pleas and an Indictment

by Thomas Fox on

For those who might have wondered if the Sessions Justice Department (DOJ) was going to enforce the Foreign Corrupt Practices Act (FCPA), that question seems to have been answered in the affirmative. In September, the DOJ and...more

COSO Framework: Fraud, Corruption and Compliance (Part I of II)

by Michael Volkov on

Global companies need to actively work to prevent fraud and corruption. Fraud and corruption go hand-in-hand. To commit bribery, bad actors have to gain access to money for unauthorized (illegal) purposes. A failure to...more

Saudi Arabia Has a Corruption Crackdown – What is Your Response?

by Thomas Fox on

What every international business person should absolutely remember that there is no country in the world which makes bribery and corruption legal by statute. That means if and when a government decides to clamp down on what...more

Alternatives to prosecution in an age of global enforcement - Global alternatives to prosecution when a corporate is facing a...

by White & Case LLP on

Businesses are increasingly becoming global, and so are enforcement actions in response to alleged corporate wrongdoing around the world. The harsh reality is that wherever there is potential corporate criminal wrongdoing,...more

It Takes a Village . . . To Commit Bribery

by Michael Volkov on

A company that commits bribery has to undergo a soul-searching examination of its operations, from top to bottom. Bribery violations come in all shapes and forms – systemic violations like Siemens, Daimler and other...more

Who Knows What Corrupt Lives in the Hearts of Men: the Telia FCPA Resolution

by Thomas Fox on

While the resolution of the Telia FCPA matter has long been awaited, the results announced in September by the Department of Justice and Securities and Exchange Commission were stunning nonetheless....more

Day 17 of One Month to More Effective Compliance for Business Ventures- Corporate Controller and Business Ventures

by Thomas Fox on

One area not often considered by the CCO as a key part of any compliance regime is the corporate Controller. The Controller generally has the responsibility to accurately record and report the financial transactions of the...more

ISO 37001: Training, Employee Concerns, and Internal Investigations (Part V of V)

by Michael Volkov on

In my final posting on ISO 37001, I review requirements for training, raising concerns and internal investigations as part of a company’s anti-bribery risk management system....more

ISO 37001: Risk Assessments, Employees, and Due Diligence Requirements (Part IV of V)

by Michael Volkov on

In Part IV of my series on ISO 37001, I examine requirements relating to risk assessments, design of policies and procedures, and due diligence requirements. Section 4.5 sets out requirements for conducting risk...more

ISO 37001: Board, Top Management and Anti-Bribery Compliance Responsibilities (Part III of V)

by Michael Volkov on

In Part III of my continuing series on ISO 37001, today I examine the board and top management’s respective responsibilities in the implementation and oversight of an anti-bribery management system....more

ISO 37001: The Good, The Bad and the Ugly (Part II of V)

by Michael Volkov on

In Part II of my continuing series, I identify in broad strokes some of the more significant positive and negative aspects of ISO 37001. While it is easy to second-guess the ISO 37001 authors, there are some interesting...more

The Halliburton FCPA Enforcement Action - Lessons for Chief Compliance Officers on Internal Controls Failures

by Thomas Fox on

One takeaway of the Halliburton-Sonangol FCPA enforcement action? Trust but verify....more

Steering the course – navigating bribery and corruption risk in private equity investments: Part 3

by Hogan Lovells on

Identifying Bribery and Corruption risk in the context of private equity investments (and M&A more generally) is key to ensuring the value of an acquisition. Companies will busy themselves with due diligence on tax,...more

Steering the course – navigating bribery and corruption risk in private equity investments: Part 1

by Hogan Lovells on

Identifying Bribery and Corruption risk in the context of private equity investments (and M&A more generally) is key to ensuring the value of an acquisition. Companies will busy themselves with due diligence on tax,...more

Where O’ Where Did Our Monitors Go? — The Telia Bribery Case

by Michael Volkov on

Just when everyone was anticipating the beginning of an uptick in FCPA enforcement in 2017, the Justice Department and the SEC delivered a resounding message to remind everyone that FCPA enforcement is here to stay. However,...more

The Fraud Triangle, Rationalizations and Compliance Programs

by Thomas Fox on

The fraud triangle is well-known to most compliance practitioners. Its third sides are pressure, opportunity and rationalization. When these three factors converge, there is danger of an ethical lapse which could lead to...more

Tribute To Gogos – New Corruption Scandal In College Sports

by Thomas Fox on

October is my annual Classic Monster Movie month tribute. I recognize it is not yet October but I wanted to begin a bit early this year as September saw the passing of Basil Gogos. He was the prime illustrator for the...more

Telia FCPA Enforcement Action: Part IV – Getting Some Monies Back

by Thomas Fox on

I have spent the past few blog posts reviewing the many lessons that can be garnered by the compliance practitioner from the Telia Company AB (Telia) Foreign Corrupt Practices Act (FCPA) resolution. However, there is one...more

The Telia FCPA Resolution: Part III – The Individuals

by Thomas Fox on

I continue my exploration of the Telia Company AB (Telia) Foreign Corrupt Practices Act (FCPA) enforcement action and the parallel actions. Today I will consider the individuals who have been criminally indicted in Sweden and...more

DOJ And SEC Bring Major FCPA Enforcement Actions Against Swedish Telecom Firm, Imposing One Of Largest FCPA Penalties In History

by Shearman & Sterling LLP on

On September 21, 2017, the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced significant enforcement actions against Telia Company AB, a Swedish telecommunications firm, for alleged...more

In the Third-Largest FCPA Enforcement Action Ever, Telia Agrees to Pay Almost $1 Billion to Resolve Bribery Inquiry in Uzbekistan;...

by Ropes & Gray LLP on

In the first blockbuster FCPA action of the Trump administration, on September 21, 2017, Swedish telecommunications company Telia agreed to pay $965 million in total penalties to the U.S. Department of Justice (“DOJ”) and...more

The Telia FCPA Resolution: Part II – The Bribery Schemes

by Thomas Fox on

Over the next few blog posts, I will be exploring the resolution and what lessons the compliance practitioner can draw from the Telia Company Foreign Corrupt Practices Act, (FCPA) enforcement action, the parallel actions and...more

The Telia FCPA Resolution, Part I

by Thomas Fox on

While the resolution of the Telia Company (Telia) Foreign Corrupt Practices Act (FCPA) matter has long been awaited, the results announced yesterday by the Department of Justice (DOJ) and Securities and Exchange Commission...more

Book Review: The Chickenshit Club

by Thomas Fox on

To my mind the most significant and important book that every Chief Compliance Officer (CCO), General Counsel (GC) and compliance practitioner needs to read is The Chickenshit Club by Pulitzer Prize winning journalist Jesse...more

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