News & Analysis as of

Corruption Compliance

This Week in FCPA-Episode 80, The Last Jedi Edition

by Thomas Fox on

Jay and I return for a wide-ranging discussion on some of the top compliance- and ethics-related stories of the week, including: 1. There are several FCPA 40th anniversary pieces going up these days. The FCPA Blog is looking...more

Star Wars Week: Part IV – Episode VII – The Force Awakens and Disruption Innovation in Compliance

by Thomas Fox on

One of the key things the Department of Justice (DOJ) has communicated over the past few months is the importance of doing compliance rather than having a paper compliance program in place. In releasing the new Foreign...more

Star Wars Week: Part III – Return of the Jedi – A good final result

by Thomas Fox on

While I am not sure how much celebrating HSBC might be doing this week, they should have pride in making it through the five-year DPA. The bank worked very hard to overcome its miss-steps and hopefully it will continue to do...more

Star Wars Week: Part II – The Empire Strikes Back – Due Diligence

by Thomas Fox on

I break due diligence down into three stages: Level I, Level II and Level III. Candice Tal, Founder and Chief Executive Officer (CEO) of Infortal Worldwide, in an article entitled “Deep Level Due Diligence: What You Need to...more

Calculating the New Balance Between Disclosure and Non-Disclosure of Potential FCPA Violations

by Michael Volkov on

The Justice Department’s new FCPA Corporate Enforcement Policy has altered the balance between disclosure and non-disclosure of FCPA violations. How is that for a profound grasp of the obvious?...more

Star Wars Week: Part I – What is Risk?

by Thomas Fox on

Whether you utilize one approach or another, analyzing the results of your risk assessment is as important as doing the risk assessment. With the recent Department of Justice (DOJ) remarks around how they will review the...more

Global Legal Insights: Bribery & Corruption, 2018 - China

by Latham & Watkins LLP on

China has had strong anti-corruption laws for many years. On 1 January 1980, the Criminal Law of the People’s Republic of China (the “PRC Criminal Law”), containing the criminal offences of bribery and corruption, came into...more

Global Legal Insights: Bribery & Corruption, 2018 - Japan

by Latham & Watkins LLP on

Japan is widely perceived to be one of the least corrupt countries in the world. Transparency International ranked Japan as the 20th least corrupt country out of 176 in the most recent Corruption Perceptions Index. The World...more

Pushing Ethics and Compliance Programs in the New FCPA Corporate Enforcement Policy

by Michael Volkov on

The Justice Department’s aggressive enforcement program, particularly in the FCPA arena, has been the primary impetus to the growth and empowerment of the corporate compliance function. The Justice Department and SEC’s FCPA...more

Compliance Under the New FCPA Enforcement Policy – Final Thoughts

by Thomas Fox on

Over the past few posts I have been exploring the Department of Justice’s (DOJ) new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA...more

Takeaways from the 34th International Conference on the Foreign Corrupt Practices Act

by K&L Gates LLP on

At the 34th International Conference on the Foreign Corrupt Practices Act held last week in Washington, D.C., industry executives, members of the defense bar, and regulators examined developments in the enforcement of the...more

Dorsey Anti-Corruption Digest - December 2017

by Dorsey & Whitney LLP on

Deputy Attorney General Rod Rosenstein announced the addition of a new Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) policy, titled the FCPA Corporate Enforcement Policy. The new policy, which was...more

New FCPA Enforcement Policy Ends the Compliance Defense Debate

by Thomas Fox on

As I continue my exploration of the new Department of Justice (DOJ) policy regarding Foreign Corrupt Practices Act (FCPA) enforcement, the FCPA Corporate Enforcement Policy (Policy), one of the things that struck me was the...more

Compliance Under the New FCPA Enforcement Policy – Clarification and Consolidation

by Thomas Fox on

Last week, the Department of Justice (DOJ) premiered a new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA Corporate Enforcement...more

Compliance Under the New FCPA Enforcement Policy – Compliance Expertise

by Thomas Fox on

Last week, the Department of Justice (DOJ) premiered a new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA Corporate Enforcement...more

Compliance Under the New FCPA Enforcement Policy – Root Cause Analysis

by Thomas Fox on

Last week, the Department of Justice (DOJ) premiered a new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA Corporate Enforcement...more

Let's Have A Really Uncomfortable Conversation

Having recently returned from three weeks of corporate engagements and conferences across nine time zones, I should be exhausted, but instead I’m exhilarated. Originally published on the FCPA Blog, www.fcpablog.com. ...more

Five Key Takeaways from DOJ’s New FCPA Corporate Enforcement Policy

by Michael Volkov on

In a significant FCPA enforcement development, DOJ’s Deputy Attorney General (“DAG”) Rod Rosenstein last announced the implementation of a new FCPA Corporate Enforcement Policy. The announcement was not a surprise based on...more

The New FCPA Corporate Enforcement Policy – A Step Forward for Compliance

by Thomas Fox on

On Wednesday, the Department of Justice (DOJ) premiered a new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA Corporate Enforcement...more

More Compliance Lessons from Wells Fargo-FOREX Trades

by Thomas Fox on

At some point, you must ask just how corrupt is an organization? What does the tone from top which says to make your numbers at all cost, translate to in operationalization? Unfortunately, we have seen yet another dramatic...more

The Economic Costs of Corruption

by Thomas Fox on

In a truly extraordinary article in the New York Times (NYT), columnist Thomas L. Freidman opened the article on his interview with Crown Prince Mohammed bin Salman (MBS) with the following, “I never thought I’d live long...more

'The Chickenshit Club' - Book Review and Author Interview

by Thomas Fox on

'The Chickenshit Club' is the most important book that every Chief Compliance Office, General Counsel, and compliance practitioner needs to read. Here's a review and interview with its author....more

Anti-Money Laundering Risks for Global Companies (Part I of III)

by Michael Volkov on

Non-financial institution companies operating in the global marketplace face ever-increasing risks of money laundering. Sophisticated criminal organizations have developed their own mechanisms and strategies to skirt money...more

DOJ Continues Run on Individual FCPA Criminal Prosecutions

by Michael Volkov on

The Department of Justice announced criminal FCPA charges against two individuals in connection with bribery payments to foreign officials in Chad and Uganda. The Justice Department’s announcement occurred on the heels of...more

Third Party Risk Management: Require ISO 37001 Certification from Your Third Parties

by Michael Volkov on

A lot of the focus on ISO 37001 so far has been on its value for companies considering certification as evidence of the quality of their own compliance program. With the SEC and DOJ both providing ample guidance to companies...more

482 Results
|
View per page
Page: of 20
Cybersecurity

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.