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Internal Controls Corporate Misconduct Anti-Corruption

Epiq

The New DOJ Position on Self-Disclosure Demands High-Functioning Compliance

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In remarks to an industry group, Matthew R. Galeotti, head of the Department of Justice (DOJ) Criminal Division, emphasized that companies may avoid criminal resolutions if they voluntarily self-disclose misconduct, fully...more

Alston & Bird

Pause and Effect: The Trump Administration Takes Aim at the FCPA

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Our White Collar, Government & Internal Investigations Team examines the impact of President Trump’s Executive Order pausing enforcement of the Foreign Corrupt Practices Act and identifies some key considerations and...more

Society of Corporate Compliance and Ethics...

Albemarle: One year later

I had many ideas for an article that would expand on recent developments in the compliance and ethics space. My working title was the creatively light “Recent Developments.” But after meeting with SCCE & HCCA’s editorial...more

The Volkov Law Group

The Evolution of the Compliance Profession

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One of the benefits of old(er) age is perspective and experience.  (As we age, we have to find the positive reasons to tout).  If there is one thing (of many) the compliance profession has demonstrated, it is that compliance...more

The Volkov Law Group

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

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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

The Volkov Law Group

The Importance of Accounting and Internal Controls (Part I of II)

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Here are some basic propositions that surround FCPA compliance. It is often underplayed that the FCPA contains more than just a bribery prohibition – the FCPA contains broad provisions, requiring accurate books and records...more

The Volkov Law Group

Compliance Program Monitoring, Testing, Audits, Assessments and Continuous Improvement (Part I of IV)

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Chief compliance officers have a lot of issues to balance on their plate.  Experienced CCOs know that it is not possible to complete every objective, balance every changing risk, and continuously improve their respective...more

The Volkov Law Group

KT Corp. Settles SEC FCPA Case for $6.3 Million (Part I of III)

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The SEC announced its first FCPA enforcement action in 2022. South Korean telecommunications company, KT Corporation, agreed to pay $6.3 million to settle FCPA violations.  As part of the settlement, KT Corp. agreed to pay...more

Goodwin

2021 Year in Review: FCPA

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A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more

WilmerHale

Bribery Act 2010: Ten Years On

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Ten years have passed since the introduction of the UK’s primary anti-corruption law, the Bribery Act 2010 (“the Act”). This article examines the extent to which the Act has lived up to its billing as the international “gold...more

Thomas Fox - Compliance Evangelist

Answering DOJ Questions on Confidential Reporting

What are some best practices regarding an internal reporting system? The 2012 FCPA Guidance stated, “An effective compliance program should include a mechanism for an organization’s employees and others to report suspected or...more

McDermott Will & Emery

[Webinar] Anti-Corruption and Compliance Training - May 28th, 10:00 am - 11:30 am EDT

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Please join McDermott and Grant Thornton on Thursday, May 28, for a webinar training on anti-corruption and compliance. This training will discuss the auditing standards on illegal acts by clients and the auditor’s...more

The Volkov Law Group

The Future of Compliance: Building Bridges (Part II of III)

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As a passionate supporter of the compliance function, I continue to advocate for compliance officers and the importance of compliance to overall governance.  Good compliance means good business – we all know that....more

Thomas Fox - Compliance Evangelist

CCO Lessons from A Charlie Brown Christmas

Delegation is always a key technique in improving productivity. However, you should not simply “shove things off your plate” but use the opportunity to give specific and new challenges to employees to help in their own career...more

The Volkov Law Group

The Current State of Compliance and Internal Audit Partnership

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Compliance officers and internal auditors are natural partners and allies in the compliance governance landscape.  As the compliance profession and influence grew, compliance officers often leaned on internal auditors for...more

The Volkov Law Group

Walmart’s Recipe for Corruption Disaster: Rapid International Growth without a Compliance Program Foundation (Part II of III)

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The Walmart case, from a big picture standpoint, represents a serious warning to all global companies committed to rapid international growth.  In the absence of a significant and sustained commitment to compliance, rapid...more

Hanzo

The Compliance Implications of Operation Varsity Blues: A Conversation with AP Capaldo-Aoun, LPEC

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On the afternoon of Monday, April 8th, 2019, I spoke with AP Capaldo-Aoun, a global compliance attorney and director of E&C at a Fortune 100 technology company, about the compliance implications of Operation Varsity Blues....more

Foley & Lardner LLP

White Collar Enforcement and the New Trump Administration: Your Top Ten Questions Answered

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Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more

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