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Foreign Corrupt Practices Act (FCPA) Corruption Risk Assessment

Thomas Fox - Compliance Evangelist

Risk Assessment Lessons from Star Trek: Balance of Terror

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

Society of Corporate Compliance and Ethics...

Third-party due diligence: Are supplier questionnaire(s) the answer?

Numerous laws (U.K. Bribery Act guidance document, German Supply Chain Act, Foreign Corrupt Practices Act resource guide, OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and...more

Thomas Fox - Compliance Evangelist

Risk Assessments

One cannot really say enough about risk assessments in the context of anti-corruption programs. This is because every corporate compliance program should be based on a risk assessment, on an understanding of your...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

The Volkov Law Group

Refreshing and Elevating Your Sanctions Compliance Program (Part II of III)

The Volkov Law Group on

Let’s move beyond the headline – trade compliance is the new FCPA.  We get it.  The next step is to do something about it.  The Justice Department has repeated this refrain – it is one of its greatest hits.  In addition, DOJ,...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - May 8th - 11th, Chicago, IL

Ideal for practitioners who have some compliance knowledge and are ready for a deeper dive, SCCE’s Basic Compliance & Ethics Academy provides comprehensive, classroom-style training in the essentials of managing a compliance...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - February 27th - March 2nd, Scottsdale, AZ

Ideal for practitioners who have some compliance knowledge and are ready for a deeper dive, SCCE’s Basic Compliance & Ethics Academy provides comprehensive, classroom-style training in the essentials of managing a compliance...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - January 23rd - 26th, Lake Buena Vista, FL

Ideal for practitioners who have some compliance knowledge and are ready for a deeper dive, SCCE’s Basic Compliance & Ethics Academy provides comprehensive, classroom-style training in the essentials of managing a compliance...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - August 22nd - 25th, Las Vegas, NV

Are you looking to better… - Support, enhance, and manage a compliance and ethics program? - Mitigate risk within your organization? - Understand the components of effective program infrastructure? SCCE’s Basic...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - May 16th - 19th, Boston, MA

Are you looking to better… - Support, enhance, and manage a compliance and ethics program? - Mitigate risk within your organization? - Understand the components of effective program infrastructure? SCCE’s Basic...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - April 11th - 14th, Washington, DC

Are you looking to better... - Support, enhance, and manage a compliance and ethics program? - Mitigate risk within your organization? - Understand the components of effective program infrastructure? SCCE’s Basic...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - March 7th - 10th, San Diego, CA

Are you looking to better… - Support, enhance, and manage a compliance and ethics program? - Mitigate risk within your organization? - Understand the components of effective program infrastructure? SCCE’s Basic...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - November 15th - 18th, Fort Lauderdale, FL

Our Basic Academies are ideal for professionals with some compliance knowledge and experience who are ready to support, enhance and manage a comprehensive compliance program. They are taught by compliance professionals,...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

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - August 9th - 12th, New Orleans, LA

Our Basic Academies are ideal for professionals with some compliance knowledge and experience who are ready to support, enhance and manage a comprehensive compliance program. They are taught by compliance professionals,...more

Thomas Fox - Compliance Evangelist

The Digital Twin and P&L of One

Innovation in compliance can come in many forms. One such form was described by Vincent M. Walden, Managing Director at Alvarez and Marsal Holdings, LLC (A&M), in his article entitled “Profit & Loss-of-One”(P&L-of-One). In...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

Thomas Fox - Compliance Evangelist

The Unaoil Execs Guilty Pleas - The Ahsanis Criminal Information

Nine years ago, on November 4, 2010, was Panalpina Settlement Day which made history for the single largest number of companies to simultaneously settle Foreign Corrupt Practices Act (FCPA)-related violations. ...more

Thomas Fox - Compliance Evangelist

Walmart FCPA Enforcement Action: Part 4 – What Does it all Mean?

I am at the end of this exploration of the Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action. This massive case came in with multiple documents, a long list of instances of bribery and corruption,...more

Burr & Forman

Walmart FCPA Settlement Shines Light On Corporate Compliance Programs

Burr & Forman on

June 20, 2019 – Walmart (NYSE: WMT) and its subsidiary, WMT Brasilia, agreed to a combined criminal penalty and disgorgement of $282M, together with WMT’s criminal guilty plea and undertakings in an NPA, to reach a global...more

White & Case LLP

Does your compliance program address UK exposure?

White & Case LLP on

Tech companies of U.S. origin tend to have compliance programs focused on U.S. laws, including the Foreign Corrupt Practices Act (the "FCPA") and relevant tax and labor laws. The UK has enacted laws covering bribery and...more

Jones Day

Anti-Corruption Regulation Survey of 41 Countries 2017–2018

Jones Day on

Welcome to the 2017-2018 edition of the Jones Day Anti-Corruption Regulation Survey. In 2017 and 2018 to date, there has continued to be an increasing awareness among multinational companies of the significance of...more

Holland & Knight LLP

Recent Debarments Highlight Growing Risk of Sanctions By Multilateral Development Banks

Holland & Knight LLP on

• Companies that operate globally face substantial risks associated with activities funded by multilateral development banks (MDBs). • Several recent debarment actions by the World Bank highlight those risks. • To...more

Thomas Fox - Compliance Evangelist

CCO as Risk Analyst

I often write about risk, risk management and the strategic use of risk by an organization. If you are not managing risk from a compliance perspective, in many ways you are simply flying blind. ...more

Thomas Fox - Compliance Evangelist

Star Wars Week: Part I – What is Risk?

Whether you utilize one approach or another, analyzing the results of your risk assessment is as important as doing the risk assessment. With the recent Department of Justice (DOJ) remarks around how they will review the...more

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