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Ethics Bribery

This Week in FCPA-Episode 77, the Home for the Holidays 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. The DOJ/SEC FCPA Guidance turned 5 years old this week. For the compliance practitioner,...more

COSO Framework: Fraud, Corruption and Compliance (Part I of II)

by Michael Volkov on

Global companies need to actively work to prevent fraud and corruption. Fraud and corruption go hand-in-hand. To commit bribery, bad actors have to gain access to money for unauthorized (illegal) purposes. A failure to...more

Day 17 of One Month to More Effective Compliance for Business Ventures- Corporate Controller and Business Ventures

by Thomas Fox on

One area not often considered by the CCO as a key part of any compliance regime is the corporate Controller. The Controller generally has the responsibility to accurately record and report the financial transactions of the...more

ISO 37001: The Good, The Bad and the Ugly (Part II of V)

by Michael Volkov on

In Part II of my continuing series, I identify in broad strokes some of the more significant positive and negative aspects of ISO 37001. While it is easy to second-guess the ISO 37001 authors, there are some interesting...more

Steering the course – navigating bribery and corruption risk in private equity investments: Part 3

by Hogan Lovells on

Identifying Bribery and Corruption risk in the context of private equity investments (and M&A more generally) is key to ensuring the value of an acquisition. Companies will busy themselves with due diligence on tax,...more

Steering the course – navigating bribery and corruption risk in private equity investments: Part 1

by Hogan Lovells on

Identifying Bribery and Corruption risk in the context of private equity investments (and M&A more generally) is key to ensuring the value of an acquisition. Companies will busy themselves with due diligence on tax,...more

A New Owner and New CEO: Will Anything Change?

by Thomas Fox on

Tilman Fertitta has purchased the Houston Rockets from current owner Les Alexander for the stunning sum of $2.2 bn. The sales price breaks the National Basketball Association (NBA) record sale of $2 billion from when the...more

The Objective of Due Diligence: To Protect Your Culture

by Michael Volkov on

There has been so much attention paid to due diligence. We have reams and reams of articles highlighting the importance of due diligence. In addition, numerous vendors of due diligence services and technologies fill the...more

Tales from the Corporate Scandal Crypt: GM, VimpelCom, VW and Wells Fargo

by Michael Volkov on

We are fascinated by corporate scandals. Since the 1980s, the US public has enjoyed unraveling corporate scandals, and vilifying corporate leaders caught in the web of deceit and misconduct. I am sure there are historical...more

This Week in FCPA-Episode 57, the Father’s Day Edition

by Thomas Fox on

This week, as their tribute to their Dad, we are guest hosted by Jay’s daughters, Millie and Michela. They lead us through a wide-ranging discussion on some of the week’s top compliance related stories, including: 1. The...more

China Compliance, From Someone Who Knows

In today’s compliance environment, though we see a robust debate on what the new US administration might mean for anti-bribery compliance, the new ISO standard, and the recent DOJ “Evaluation of Corporate Compliance Programs”...more

Day 3 of One Month to Better Investigations and Reporting-the Investigation Protocol

by Thomas Fox on

Your company should have a detailed written procedure for handling any complaint or allegation of bribery or corruption, regardless of the means through which it is communicated. The mechanism could include the internal...more

Operationalizing Compliance: Part V – Controller’s Office

by Thomas Fox on

This week I have engaged in a series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I have been...more

From Bottom Bunk to Top Mind

I recently had the honor of being named to Compliance Week’s list of Top Minds for 2017, earning the title of “The Great Communicator” from Bill Coffin, Donna Rice, and the CW team....more

This Week in FCPA-Episode 53, the I left my heart in San Francisco edition

by Thomas Fox on

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Brazilian President Temer comes under corruption fire? 2. The turmoil at FIFA continues as FIFA’s...more

Talking About Bribery in the Country Where I Bribed

I recently returned from a week in Amsterdam, addressing front-line compliance challenges, and attending several anti-corruption conferences. It was a surreal experience for me, for in 2003 I paid a “Dutch Agent approximately...more

Code of Conduct Week: Part III – Design of Your Code of Conduct

by Thomas Fox on

Today I continue my Code of Conduct exploration with Eric Morehead, Principal of Morehead Compliance Consulting. After having reviewed the legal requirement and business purpose in Part I, the structure and form of your Code...more

LRN Compliance Program Effectiveness Report: Part I (and Farewell to Chuck Berry)

by Thomas Fox on

Last week I interviewed Susan Divers, Senior Advisor at LRN Corporation, on the company’s 2016 Ethics and Compliance Program Effectiveness Report (Report). The Report was a fascinating review of the evolution of compliance...more

My China Compliance Diary

When my supervision (probation) ended in January 2017, the US District Court in DC released my passport, and I could once again travel internationally. And with that milestone, a note of thanks to all the international event...more

Judged by the Company You Keep

by NAVEX Global on

Earlier this month news broke that the venerable British automaker Rolls-Royce had settled an international prosecution alleging that the company’s third-party intermediaries bribed local officials in Asia. The company agreed...more

ISO 37001: Let’s Talk Specifics

by NAVEX Global on

Some, though certainly not all, of the dust has settled since ISO 37001 published last fall. As compliance professionals grapple with the new standard, we thought it would be interesting to use the power of social media to...more

The Real Explanation for the Record Year for FCPA Enforcement

by Michael Volkov on

All the FCPA prognosticators, predictors and paparazzi have missed the boat on understanding what happened this year – 2016, to make this a record year in FCPA enforcement. As a former public servant for over 20 years, I am...more

FCPA Predictions for 2017 (Part III of III)

by Michael Volkov on

With the new incoming administration, everyone is busy predicting major changes in DOJ FCPA enforcement. I do not share this view. Frankly, FCPA enforcement is more bipartisan than other controversial enforcement programs...more

Gluten Free Compliance

This past November, I had the pleasure of sitting down with Sean Freidlin, Marketing Manager of Compliance & Ethics at SAI Global, www.saiglobal.com  at The Little Beet Restaurant in NYC, to discuss my history with...more

The SEC’s Continuing Refinement of Internal Controls Enforcement

by Michael Volkov on

My good friend and colleague, Tom Fox, has written an interesting post on the SEC’s recent United Airlines settlement for $2.4 million for domestic bribery. As Tom has noted, the interesting aspect of the SEC’s enforcement...more

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