News & Analysis as of

Corruption Third-Party Risk

Thomas Fox - Compliance Evangelist

Managing Third Parties

The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the life cycle management of third parties, most compliance practitioners understand the need for a...more

The Volkov Law Group

DOJ’s Latest Opinion Release Underscores Absence of Corrupt Intent and Lack of Business Purpose

The Volkov Law Group on

The Justice Department has had a slow year in FCPA enforcement (another profound grasp of the obvious).  The reasons for this may be a question of timing elements in the pipeline of cases....more

Morgan Lewis

Anti-Bribery And Corruption Survey Report

Morgan Lewis on

Survey: Tech gaps, third parties pose biggest ABAC threats - Compliance professionals surveyed regarding their anti-bribery and corruption efforts (ABAC) indicated resource support deficiencies in areas including staffing...more

Thomas Fox - Compliance Evangelist

Building a Stronger Culture of Compliance Through Targeted and Effective Training: Part 4-A Training Program for 3rd Parties

Welcome to a special 5 part blog post series on building a stronger culture of compliance through targeted and effective training, sponsored by Diligent. Over this series I will visit with Kunal Agrawal, Director of Customer...more

American Conference Institute (ACI)

[Event] 13th West Coast Forum on FCPA Enforcement and Compliance - June 14th - 15th, San Francisco, CA

Hosted by American Conference Institute, the 13th West Coast Forum on FCPA Enforcement and Compliance returns for another exciting year, providing the opportunity to connect with decision-makers from your industry, gather...more

Society of Corporate Compliance and Ethics...

[Webinar] ’GOAT’ Compliance Programs - April 12th, 12:00 pm - 1:30 pm CT

Learning Objectives - How to risk rate third parties - How to conduct a third-party audit - Corruption indicators to identify during an audit...more

American Conference Institute (ACI)

[Event] Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Hosted by American Conference Institute, the Mexico Summit on Anti-Corruption & Compliance Programs returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance...more

The Volkov Law Group

Adjusting Your Perspective — Identifying Your Real Third-Party Risks (Part II of V)

The Volkov Law Group on

Compliance professionals are always looking for ways to collaborate and support internal business partners.  Through the years, compliance professionals have devoted significant energy to building partnerships with the...more

The Volkov Law Group

Lessons Learned from the KT Corp. SEC FCPA Settlement (Part III of III)

The Volkov Law Group on

Even though the size of the KT Corp. SEC enforcement action is relatively small, the underlying misconduct provides a number of important lessons learned. ...more

The Volkov Law Group

Keeping Track of Third Party Risks – Bribery and Sanctions

The Volkov Law Group on

We have heard it over and over, again and again – third-parties pose significant risks of bribery for all global businesses.  Almost every FCPA enforcement action includes some form of third-party misconduct.  The current...more

Proskauer - Minding Your Business

Online Marketplaces Could Expose Third-Party Sellers to Price Gouging Liability

On July 2, 2021, a group of consumers filed a putative class action in Washington District Court alleging Amazon engaged in unlawful price gouging during the COVID-19 pandemic on a variety of products. The case is noteworthy...more

The Volkov Law Group

WPP SEC FCPA Enforcement Action: Lessons Learned (Part III of III)

The Volkov Law Group on

The SEC’s FCPA enforcement action against WPP presents a number of important lessons learned, ranging from third-party risk management, properly responding to employee complaints and red flags, and failure to integrate...more

The Volkov Law Group

Lessons Learned: Foster Wheeler FCPA Settlement Underscores Danger of Third-Party Risks (Part III of III)

The Volkov Law Group on

We all know and hear about third-party risks – over and over again. Despite this recurring theme, organizations continue to pay the price for failing to address third-party issues.  It does not take a rocket scientist to...more

American Conference Institute (ACI)

[Event] Anti-Corruption London - November 2nd - 3rd, London, United Kingdom

C5's 15th International Conference on Anti-Corruption London will take place November 2 – 3, 2021 in Millennium Hotel London Knightsbridge, London. Join your peers for the IN-PERSON reunion of the legal and compliance...more

The Volkov Law Group

Foster Wheeler FCPA Action: Dancing with the Devil – Risky Third Parties (Part II of III)

The Volkov Law Group on

FCPA settlement actions often underscore specific compliance risks for legal and compliance professionals. If there ever was a case where third-party risks were bungled, and even intentionally embraced, the Foster Wheeler...more

The Volkov Law Group

FinCEN Issues Human Trafficking Advisory (Part II of II)

The Volkov Law Group on

Human traffickers, like all criminals, rely on the international financial system to facilitate their crimes and to disguise proceeds from their illegal activities.  Traffickers open bank accounts to deposit and launder...more

The Volkov Law Group

Letting Third Parties Do the Dirty Work

The Volkov Law Group on

We all know it when we see it – a recurring fact pattern in which a company enlists a corrupt third party intermediary for one purpose (and one purpose only) – to pay a bribe.  Let me give you a few examples....more

Hogan Lovells

Containing the corruption and fraud virus

Hogan Lovells on

COVID-19 is changing the nature of corruption and fraud. The risks they bring are mutating, and the pandemic is drastically altering the way such risks are detected and mitigated. ...more

Holland & Knight LLP

Lessons Learned from the Airbus Anti-Corruption Settlements

Holland & Knight LLP on

In late January 2020, Airbus agreed to pay nearly $4 billion and to take a number of remedial measures in order to resolve alleged corruption violations with the French National Financial Prosecutor's Office (PNF), the United...more

Thomas Fox - Compliance Evangelist

The Wild Wild West and ComTech

Compliance has been pushed more to the forefront in anti-money laundering (AML). As banking institutions, financial institutions and the financial services industries continue to tighten and strengthen AML controls, criminals...more

The Volkov Law Group

2019 OFAC Sanctions Enforcement Review (Part I of II)

The Volkov Law Group on

While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement.  OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions.  That is quite an increase...more

Foodman CPAs & Advisors

Instituciones Financieras y el FCPA

La Ley de Prácticas Corruptas en el Extranjero (“Foreign Corrupt Practices Act – FCPA”) prohíbe el pago de sobornos a funcionarios extranjeros para ayudar a obtener o retener negocios.  Exige que las empresas cuyos valores se...more

Foodman CPAs & Advisors

Financial Institutions and the FCPA

The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business.  It requires companies whose securities are listed in the US to maintain books and...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 5: Lessons Learned for the Compliance Professional

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action - Part 4: The Double Whammy in Penalties

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

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