Daily Compliance News: May 19, 2025, The Definition of Corruption Edition
10 For 10: Top Compliance Stories For the Week Ending May 10, 2025
Compliance into the Weeds: USRA Declination Case Study - Self-Disclosure Best Practices
Daily Compliance News: April 8, 2025, The End of Monitors Edition
10 For 10: Top Compliance Stories For The Week Ending April 5, 2025
2 Gurus Talk Compliance: Episode 48 – The March Madness Edition
10 For 10: Top Compliance Stories For The Week Ending, March 22, 2025
Regulatory Ramblings: Episode 65 – The Trump Administration’s Decision to Halt FCPA Enforcement – The Implications for Asia and the World with Tom Fox, Malcolm Nance, and Philip Rohlik
Daily Compliance News: March 19, 2025, The Why CISOs Quit Edition
10 For 10: Top Compliance Stories For the Week Ending March 15, 2025
Episode 356 -- Trump Administration Hits Pause on FCPA Enforcement
Episode 351 -- Deep Dive into the AAR FCPA Settlement
Episode 350 -- Deep Dive into McKinsey FCPA Case
Corruption, Crime & Compliance: BIT Mining Resolves FCPA Case for $10 Million and CEO Pan Indicted
Episode 349 -- Review of the BIT Mining FCPA Settlement
Episode 345 -- Raytheon Pays $950 Million to Resolve Fraud, FCPA, ITAR and False Claims Act Violations
Episode 344 -- SEC Settles FCPA Case with Moog for $1.7 Million
Episode 339: Four Sanctions Cases Everyone Should Know
Episode 338 -- Deep Dive into the Deere SEC FCPA Case
Wicked Coin: The "Fat Leonard" Scandal
On this episode of Culture & Compliance Chronicles, Amanda Raad and Nitish Upadhyaya from Ropes & Gray’s Insights Lab, and Richard Bistrong of Front-Line Anti-Bribery, are joined by Danny Mayhew, the global head of...more
Significant Expansion to Corporate Criminal Liability Becomes Law in the United Kingdom - On 26 October 2023, the Economic Crime and Corporate Transparency Act (the Act) became law. Under the Act, corporations will become...more
It is no great secret that criminal enforcement in the United Kingdom against corporations has lagged behind our counterparts in the United States and other jurisdictions. In recent years the UK government has introduced a...more
Innovation in compliance can come in many forms. One such form was described by Vincent M. Walden, Managing Director at Alvarez and Marsal Holdings, LLC (A&M), in his article entitled “Profit & Loss-of-One”(P&L-of-One). In...more
Most experts agree that whichever regulatory jurisdiction an organisation is subject to, there are five common fundamentals involved in providing effective corporate compliance....more
In a recent update to its internal guidance, the UK Serious Fraud Office provides insight into the general approach its investigators may take for evaluating organizations’ compliance programs—an approach similar to that of...more
Growing Chinese illicit finance threats, vulnerabilities, and exposure are combining to increase illicit financing risk in the international financial system, judging from a series of recent advisories, sanctions actions,...more
I am in a multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand and implement some of the key concepts of the Framework into your...more
We conclude our exploration of the recently released Evaluation of Corporate Compliance Programs – Guidance Document(2019 Guidance), which was announced(ECI speech) by Assistant Attorney General Brian Benczkowski at the...more
Weirdly, Volkoff informs today’s post and not simply because of President Trump’s fawning over all things Russian. We wrap-up the blog series about the continuing dangers of shell companies, as articulated by Ryan C. Hubbs,...more
This week I am posting a five-part series on FCPA compliance issues. While there have been many advances in the anti-corruption ethics and compliance field, there is still more work to do to advance effective strategies for...more
As more countries enter into the anti-corruption enforcement world, companies face exponential risks of detection and enforcement. Recently, Deputy Attorney General Rosenstein has commented on the need to avoid unfair...more
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
Foreign Corrupt Practices Act ("FCPA") - For energy, mining, and resources companies, the cost of corruption—and getting caught—is real. Less than two months ago, Odebrecht S.A. was ordered by a U.S. federal judge to pay a...more
When speaking to clients or potential clients, the question of risk of enforcement is the moose on the table. Sometimes, the question gets asked and other times, the subject is never discussed. To be fair, it is not an easy...more
Last week, a colleague asked me what I thought the Trump administration might hold for Foreign Corrupt Practices Act (FCPA) enforcement specifically and for the greater compliance discipline in general. I have been exploring...more
The FCPA Guidance notes that one of the ten hallmarks of an effective compliance program is around mergers and acquisitions (M&A), in both the pre and post-acquisition context. A company that does not perform adequate FCPA...more
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
In the wreckage of a corporate FCPA enforcement action, a company has to answer two important questions. First, how did the conduct occur without senior executives and the Board learning or suspecting that such conduct...more
It was like a bolt out of the blue – United Airlines’ CEO and two senior executives hastily announced their resignation as a result of their involvement in a bribery scandal with the New York Port Authority....more
I am always surprised at creative links between compliance principles and major historical events and concepts....more