News & Analysis as of

The Foreign Corrupt Practices Act Chief Compliance Officers

The Foreign Corrupt Practices Act is a United States Federal law enacted in 1974 to create transparency and prevent bribery for U.S.-based corporations conducting business overseas.

Rosenstein Announces Permanent FCPA “Pilot Program,” Presumption of Declination When Self-Reporting, but Difficult Choices Remain

by Ropes & Gray LLP on

On Wednesday, November 29, 2017, in remarks at the 34th International Conference on the Foreign Corrupt Practices Act (“FCPA”), Deputy Attorney General Rod J. Rosenstein announced a revised FCPA Corporate Enforcement Policy...more

Deputy Attorney General Rod Rosenstein Announces Revised FCPA Corporate Enforcement Policy

by Shearman & Sterling LLP on

On November 29, 2017, Deputy Attorney General Rod Rosenstein delivered remarks at the 34th International Conference on the Foreign Corrupt Practices Act (“FCPA”), in which he announced a revised FCPA Corporate Enforcement...more

DOJ Expands and Codifies Policy Incentivizing Corporations to Voluntarily Self-Disclose FCPA Violations

by Latham & Watkins LLP on

The revised FCPA Corporate Enforcement Policy signals DOJ’s emphasis on corporate voluntary self-disclosure, rewarding cooperating companies with a presumption in favor of declination and reductions in penalties. Please...more

New FCPA Enforcement Policy presumes declination for companies that voluntarily disclose, cooperate and remediate

by DLA Piper on

The US Department of Justice (DOJ) has issued a bold new FCPA enforcement policy that offers the presumption of a declination to companies that voluntarily report Foreign Corrupt Practices Act (FCPA) violations, cooperate...more

U.S. Department of Justice Adopts New FCPA Corporate Enforcement Policy to Enhance FCPA Pilot Program

When a company learns that an employee or third-party business partner may have bribed a foreign official, it is never an easy question as to whether the company should turn itself in to the U.S. government. On November 29,...more

DOJ Announces Changes to FCPA Corporate Enforcement Policy

On November 29, 2017, the US Department of Justice (DOJ) issued a revised Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy and sweetened the deal for companies that self-report instances of foreign bribery....more

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

Everything Compliance Reports from the SCCE 2017 Compliance & Ethics Institute [eBook]

by Thomas Fox on

In October 2017, nearly 2000 compliance professionals gathered in Las Vegas for the annual Society of Corporate Compliance and Ethics (SCCE) Compliance and Ethics Institute. The event was a great success for all involved, it...more

How to Communicate the ‘Vision Thing’

by Thomas Fox on

Think about the task facing new Uber Chief Executive Officer (CEO), Dara Khosrowshahi. He is working to overhaul a toxic corporate culture, while dealing with regulators literally across the globe. ...more

A Magical Nine Days: The World Series, Houston Astros, and What It Means for Chief Compliance Officers

by Thomas Fox on

The fall saw their first World Series Championship in the 55-year history of the Houston Astros. What does it mean for the compliance practitioner?...more

It Takes a Village . . . To Commit Bribery

by Michael Volkov on

A company that commits bribery has to undergo a soul-searching examination of its operations, from top to bottom. Bribery violations come in all shapes and forms – systemic violations like Siemens, Daimler and other...more

Episode 8 -- The Critical Importance of Beneficial Ownership to Compliance

by Michael Volkov on

In the aftermath of the Panama Papers scandal and increased focus on shell companies and hidden ownership interests, US enforcement and regulatory agencies are increasing focus on beneficial ownership of related entities. In...more

Astros Garner First World Series Win – Execution of Compliance in the Middle

by Thomas Fox on

In compliance you often times need to be a superior utility player who is good at every job. There are multiple lessons. First and foremost is the problem of siloing in corporate America. This concern of siloing even...more

Who Knows What Corrupt Lives in the Hearts of Men: the Telia FCPA Resolution

by Thomas Fox on

While the resolution of the Telia FCPA matter has long been awaited, the results announced in September by the Department of Justice and Securities and Exchange Commission were stunning nonetheless....more

Using Strategic Risk to Your Advantage

by Thomas Fox on

I am beginning to feel this week’s theme becoming all-encompassing. As hard as I might try, it looks like it will be the Houston Astros second World Series appearance. During the first one back in 2005, I was in the corporate...more

The Halliburton FCPA Enforcement Action - Lessons for Chief Compliance Officers on Internal Controls Failures

by Thomas Fox on

One takeaway of the Halliburton-Sonangol FCPA enforcement action? Trust but verify....more

An Exploration of Soft Skills in Remediation for the Chief Compliance Officer

by Thomas Fox on

Many have focused on the more technical aspects of the remediation component of a potential Foreign Corrupt Practices Act compliance violation. I wanted to explore the soft skills that a CCO must use, both internally and...more

Lessons for Compliance Officers from Hurricane Harvey and Other Historic Weather-Related Events

by Thomas Fox on

Lessons for the corporate compliance professional from Hurricane Harvey and other weather-related disasters....more

Compliance Lessons From Burner Phones

by Thomas Fox on

Hunter S. Thompson once said that when the going gets weird, the weird turn pro. It turns out that amateurs can get weird too. The University of Mississippi football program, which is under a self-imposed postseason ban and...more

Slippery Slopes: “Broken Windows” and Employee Misconduct

by Michael Volkov on

Criminologists have debated for years the efficacy of the law enforcement strategy of “broken windows.” In simple terms, the theory suggests that minor infractions or petty crimes should be vigorously prosecuted in order to...more

Your Company Brand and Ethical Behavior

by Thomas Fox on

Last week, I was interviewed by David Banks, the Senior Content Marketing Manager at NAVEX Global, for the firm’s blog. One of the questions he posed to me struck me and it was “When it comes to contributing to a greater...more

The Emperor Has No [Compliance Program]

by Michael Volkov on

At the outset, I have to apologize for the title but during my morning bike ride I usually come up with blog posting titles. But moving past the trite title, I have a point to make....more

Using Data to Improve Your Compliance Bench Strength

by Thomas Fox on

In the September edition of One Month to a More Effective Compliance Program, I am focusing on innovation in compliance. There are many ways to innovate through the use of data. One of the interesting ways is through hiring...more

Day 4 of One Month of Innovation in Compliance-Welcome to ComTech

by Thomas Fox on

What will be the role of Artificial Intelligence (AI) in compliance going forward? LawTech had disrupted the legal profession and how it is reshaping many areas of private practice. I found the article had multiple...more

Soft Skills in Remediation: Part V – Post Resolution

by Thomas Fox on

I conclude my five-part series on the soft skills a Chief Compliance Officer (CCO) needs to employ when working through the remediation component of a potential Foreign Corrupt Practices Act (FCPA) compliance violation. I...more

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