The Bribery Act: To Disclose or Not To Disclose?
FCPA Compliance and Ethics Report-Episode 19 with Barry Vitou on Bribery Act Updates
Just when we thought 2016 was over and we could all breathe a sigh of relief, DOJ and the SEC have continued to run with a string of new enforcement actions. To all of those prognosticators, paparazzi, commentators, chicken...more
Whom to suspend during any Foreign Corrupt Practices Act (FCPA) investigation is always a delicate question to answer. Unfortunately there is never an easy answer. As the Volkswagen (VW) emission-testing scandal continues to...more
The legal and compliance landscape is changing quickly—it’s up to organisations that do business in the U.K. to strengthen their compliance programmes to meet these new challenges. In this whitepaper, Andrew Foose, vice...more
The key to being a successful (FCPA) prognosticator is never to keep score. If you do, you are likely to be disappointed. Instead, I follow the strategy of calculated distraction – for example, I predicted last year...more
Whatever you might think of where his career went, Elton John had some great early stuff. I still rank Tumbleweed Connection right up there as one of my favorite albums of all-time. And while it was packed with some great...more
The U.K.’s Serious Frauds Office prevailed in its first overseas corruption trial, securing a jury verdict in its favor and against two former Innospec executives. The case stems from a referral by the DOJ following FCPA...more
FDIC Guidance on Deposit Advance Products - On November 21, the FDIC issued final supervisory guidance to FDIC-supervised financial institutions with respect to the risks imposed by certain deposit advance products. ...more
On November 20, 2013, during a panel presentation at the 30th International Conference on the Foreign Corrupt Practices Act (“FCPA”), current and former prosecutors from the United States and the United Kingdom discussed the...more
Doing something ‘by the book’ means more than following a process. It means following that process during high stress times. One of the things that I think gets missed when discussing compliance programs is the need for rigor...more
This past weekend I saw the remaining members of The Who perform in their Quadrophenia Tour. While I had seen Roger Daltry perform the rock opera Tommy, I had never seen Pete Townsend in concert. To say I was blown away would...more
As almost everyone knows, Lance Armstrong spoke for the first time about his performance enhancing drug (PED) use recently on Oprah. On the first night he admitted for the first time that he used PEDs during his seven wins at...more
One of the great plays and movies that I enjoy is ‘Glengarry Glen Ross’. As you might expect with anything that David Mamet pens the dialogue is absolutely spot on, fast paced and non-stop. The action generally revolves...more
In December 2012 the BBC online service reported that Rolls-Royce Motor Cars Limited (Rolls-Royce) was in talks with the UK Serious Fraud Office (SFO) regarding potential allegations of bribery and corruption in Indonesia and...more