News & Analysis as of

Corruption Johnson Controls

Thomas Fox - Compliance Evangelist

The Mississippi Company – When Things Get Too Complicated

I thought about the Mississippi Company in the context of the Johnson Controls, Inc. (JCI) Foreign Corrupt Practices Act (FCPA) enforcement action. The bribery scheme involved was quite sophisticated with “a multi-stepped...more

The Volkov Law Group

How Do You Define a Compliance Program Failure?

The Volkov Law Group on

In our perpetual quest for simplicity, sometimes we fail to understand the complexity of an issue. In the corporate world, if you ask board members and CEOs how they would define a compliance program ”failure,” I am sure...more

Troutman Pepper

Lessons Learned from the FCPA Pilot Program's First Six Months

Troutman Pepper on

The guidance issued by the DOJ in connection with the Pilot Program and recent declinations state that disclosure, remediation and cooperation are essential to any favorable resolution with the government. Six months...more

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