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The Volkov Law Group

Albemarle’s Reliance on Third-Parties to Execute Bribery Schemes (Part II of III)

The Volkov Law Group on

Albemarle’s bribery schemes look and sound like text-book examples of third-party agents being paid high commissions as a way to funnel bribery payments to foreign officials at state-owned oil refineries.  However, as usual,...more

The Volkov Law Group

Fresenius Medical’s Bribery Conduct Precludes Declination (Part II of III)

The Volkov Law Group on

Fresenius Medical came close to earning a declination under the FCPA Corporate Enforcement Policy. Unfortunately, Fresenius’ effort fell short — but it came close. Fresenius Medical operates more than 3700 dialysis clinics...more

The Volkov Law Group

United Technologies Pays $13.9 Million to Settle FCPA Charges (Part I of II)

The Volkov Law Group on

The SEC’s FCPA Unit had a good week last week – they announced a second FCPA settlement along with the Sanofi case. The latest to fall was United Technologies that agreed to pay $13.9 million for bribes paid by its elevator...more

Jones Day

Department of Justice Fraud Section Provides Guidance on Evaluating Corporate Compliance Programs

Jones Day on

On February 8, 2017, the United States Department of Justice ("DOJ") Fraud Section published a blueprint for assessing corporate compliance efforts, titled "Evaluation of Corporate Compliance Programs" ("Guidance"). It...more

Thomas Fox - Compliance Evangelist

Data Analytics Week – Part IV: Third Parties and Duplicate Invoices

I continue my exploration of the use of data analytics in a best practices compliance program. Today we look at how data analytics can be used to help detect or prevent bribery and corruption where the primary sales force...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 157-Training of Third Parties Under the FCPA

In this episode I discuss the training of third parties under the FCPA. I review the DOJ/SEC FCPA Guidance on this issue; the risk ranking of third parties to help deliver your training; the types of training you can utilize...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 91, Internal Controls for Third Parties Under the FCPA, Part II

In this episode, I continue my exploration of internal controls around third parties in a FCPA compliance program, with Henry Mixon. ...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 63-Managing the Third Party Relationship Under the FCPA, Part I

In this episode I being a two part series on how to manage your third party relationships under the FPCA and UK Bribery Act. In this episode, steps 1-the Business Justification and Step 2-the Questionnaire. ...more

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