FCPA Survival Guide - Step 8 - Investing in Compliance
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
Compliance Tip of the Day – Compliance Lessons from the Albemarle FCPA Enforcement Action
FCPA Survival Guide: Step 1 - Self-Disclosure
All Things Investigations: Compliance Lessons from Gunvor and Trafigura Enforcement Actions
Corruption, Crime & Compliance: Deep Dive into The Trafigura FCPA Settlement
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
Compliance into The Weeds: Trafigura FCPA Enforcement Action
Corruption, Crime & Compliance: Deep Dive into The Gunvor FCPA Settlement
Episode 314 -- A Deep Dive into Gunvor's FCPA Settlement
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 311 -- Tom Fox on FCPA Enforcement: Self Disclosure and Recidivism
Episode 307 -- Sanctions Enforcement Review and Predictions for 2024
Episode 305 -- Deep Dive into SAP FCPA Settlement
Compliance Into The Weeds: The SAP Foreign Corrupt Practices Act Enforcement Action
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
By using risk-based monitoring, you can begin to see things in “almost real-time, time-based trends of real data that you can then jump on and try to make adjustments before things get really wacky.” The implications to the...more
This week I have devoted my blog posts to thinking about the management of risk by considering the tools of forecasting, risk assessment and risk-based monitoring. I have been assisted on this journey by Ben Locwin, Director...more
Today I continue my exploration of risk in compliance by starting a consideration of risk-based monitoring. As I have the previous two days, I honor a television star who died last week and today it is Mike Connors. While...more
Ten years ago the standard anticorruption policy was nearly exclusively FCPA-focused. DOJ and SEC enforcement actions were the primary, if not the only, concern for corporate executives and board members. The UK Bribery Act...more
In the last several years, the U.S. has been aggressively enforcing laws governing exports and international conduct. This is amply illustrated by the continuing imposition of large penalties on multinational companies for...more
While the Foreign Corrupt Practices Act (“FCPA”) is an extremely complex act, there are two common FCPA violations of which automotive companies with international operations should be particularly sensitive. We recently...more
As our previous posts illustrate, violations of the Foreign Corrupt Practices Act (“FCPA”) can carry a hefty cost. Two issues are commonly the impetus for FCPA violations and, practically speaking, pose significant FCPA...more
Anti-corruption issues continue to present significant risks in acquisition and investment transactions because regulators continue robust enforcement in this area and emerging markets often present the greatest economic...more