News & Analysis as of

Corruption

Crack-down on the property market - register of beneficial ownership to go live in 2021

by Dentons on

Last year the government announced its intention to introduce a public register revealing the owners of overseas companies buying property in the UK. It has just announced plans for that register to be introduced and to go...more

McKinsey, South Africa and the FCPA

by Thomas Fox on

Do you recall the boycott of South Africa from the 1970s and 1980s as a lexicon of the global fight against apartheid? The boycott extended from business to sporting events and everything in between. The campaign was one of...more

The Root Cause Analysis

by Thomas Fox on

One new and different item laid out in the Evaluation of Corporate Compliance Program (Evaluation), supplementing the Ten Hallmarks of an Effective Compliance Program from the 2012 FCPA Guidance, was the performance of a root...more

Three Simple Steps to Improve Your Corporate Culture

by Michael Volkov on

What exactly does “corporate culture” mean?  Compliance professionals often talk about how important “tone from the top” or the “mood in the middle” is, but what does that really mean?...more

U.S. Targets Human Rights Abusers and Corrupt Actors Worldwide – Key Takeaways from the Potent New Sanctions

On December 20, 2017, President Trump issued Executive Order 13818 (the “E.O.”) implementing provisions of the Global Magnitsky Human Rights Accountability Act (“Global Magnitsky Act”) (enacted into law in December 2016),...more

Time to Test and Audit Your Compliance Program

by Michael Volkov on

We all enjoy citing government sources for guidance on an effective ethics and compliance program. Whether it is the United States Sentencing Guidelines, the Justice Department’s and SEC’s FCPA Guidance, Health and Human...more

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS – Keppel Offshore Reaches Deal with DOJ and Guilty Plea by Counsel Unsealed – On December 22, 2017, Keppel Offshore & Marine Ltd. (KOM), a Singapore based company that operates shipyards and...more

Dorsey Anti-Corruption Digest - January 2018

by Dorsey & Whitney LLP on

Keeping ahead of global anti-corruption trends is critical in today’s business markets. The Dorsey Anti-Corruption Digest, which puts global trends at your fingertips, puts you ahead. The deep experience of the Dorsey...more

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS – Keppel Offshore Reaches Deal with DOJ and Guilty Plea by Counsel Unsealed – On December 22, 2017, Keppel Offshore & Marine Ltd. (KOM), a Singapore based company that operates shipyards and...more

Five Major Compliance Predictions for 2018

by Michael Volkov on

When you look back on the rise of the ethics and compliance profession, you cannot ignore the history of accomplishments. It is easy to minimize these accomplishments as a reaction to the government’s aggressive FCPA...more

Mexico’s AML Regime Evaluated by the FATF: Systemic Improvement, but Suspicious Transaction Reporting and Law Enforcement Efforts...

by Ballard Spahr LLP on

Last week, the Financial Action Task Force (“FATF”) issued a report concluding that Mexico needs to “step up efforts in pursuing money launderers.” ...more

Responding to Investigative Findings

by Thomas Fox on

Most companies understand a the need for an investigative protocol or bringing in experienced investigative counsel should a substantive Foreign Corrupt Practices Act (FCPA) allegation arise. However what is not as well known...more

U.S. Implements Global Magnitsky Sanctions Targeting Corruption and Human Rights Abuses Worldwide

by Kelley Drye & Warren LLP on

On December 20, 2017, the President issued Executive Order 13818 implementing new sanctions against human rights abusers and persons involved in corruption pursuant to the Global Magnitsky Human Rights Accountability Act...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

An overview of last Friday’s jobs report, which saw the US adding fewer jobs than expected but also tracked a welcomed increase in wages for the least-educated workers....more

Speed Bump Or Dead End? The 2018 Retrial Prospects For Sen. Menendez

by Ifrah PLLC on

This holiday season was undoubtedly festive for Senator Bob Menendez, whose corruption trial ended with a deadlocked jury in mid-November. The Department of Justice (DOJ) has yet to announce whether it will elect to re-try...more

Operationalizing Compliance: Conduct at the Top, Accountability Are Key

Almost one year ago, in February of 2017, the U.S. Department of Justice (DOJ) Fraud Section released the Evaluation of Corporate Compliance Programs guidance, which references the FCPA Resource Guide and the Hallmarks of...more

New Sanctions Imposed For Human Rights Abuses and Corruption – a Harbinger For Business in 2018?

by Baker Donelson on

On December 21, the U.S. Treasury Department announced the implementation of a new global sanctions regime under the Magnitsky Human Rights Accountability Act (the “Global Magnitsky Act”). President Trump issued an Executive...more

Justice Department Closes Out 2017 with 2 FCPA Actions: Keppel Offshore and Marine and Embraer Individual

by Michael Volkov on

The Department of Justice finished 2017 with two significant FCPA enforcement actions, and fittingly, one was a corporate settlement and another was an individual criminal guilty plea. The Justice Department’s final FCPA...more

2018 FCPA Predictions (Part II of II)

by Michael Volkov on

I always take a deep breath when starting this posting – not that I am the kiss of death, but sometimes my predictions come true and most times they do not. But with that caveat, I am brave enough to venture into 2018 and...more

The Compliance Function in an Organization

by Thomas Fox on

The role of the compliance professional and the compliance function in a corporation has steadily grown in stature and prestige over the years. In the 2012 FCPA Guidance (Guidance), under Hallmark Three of the 10 Hallmarks of...more

Trump Administration Establishes New Sanctions Regime Targeting Human Rights Abusers - Also Expands Existing Sanctions on...

by Holland & Knight LLP on

The Trump Administration rounded out the year with two sanctions-related actions: The first involved creating a new program regarding human rights abusers and global corruption; the second involved adding several individuals...more

CCO Authority and Independence

by Thomas Fox on

Why is the focus on the CCO role now concerned with authority and independence? The role of the Chief Compliance Officer (CCO) has steadily grown in stature and prestige over the years....more

2017 FCPA Year in Review (Part I of II)

by Michael Volkov on

With the close of 2017, FCPA enforcement continues as a major priority for the US Department of Justice. Notwithstanding fears and concerns that the new administration would turn its back on FCPA enforcement, the Justice...more

Red Notice Newsletter - December 2017

ANTICORRUPTION DEVELOPMENTS – Keppel Offshore Reaches Deal with DOJ and Guilty Plea by Counsel Unsealed – On December 22, 2017, Keppel Offshore & Marine Ltd. (KOM), a Singapore based company that operates shipyards...more

What is Effective Compliance Training?

by Thomas Fox on

The communication of your anti-corruption compliance program is something that must be done on a regular basis to ensure its effectiveness. The FCPA Guidance explains, “Compliance policies cannot work unless effectively...more

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