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Third-Party Due Diligence Anti-Corruption

NAVEX

What a New SEC Enforcement Sweep Is Really Telling Us

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Attention all compliance officers at large technology companies – have you checked your mail lately? Because you might find a letter from the Securities and Exchange Commission with FCPA risk written all over it....more

American Conference Institute (ACI)

[Virtual Event] Foreign Corrupt Practices Act New York - June 2nd - 3rd, 10:00 am - 4:00 pm EDT

ACI’s New York Conference on Foreign Corrupt Practices Act is returning in a virtual format on June 2 – 3, 2021. Once again, this anti-corruption event will gather the key stakeholders: senior government officials, industry...more

NAVEX

Classifying Your Third Parties: An Essential Third-Party Due Diligence First Step

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From a corruption risk perspective, companies should be looking at their third parties that act in a representative capacity. Look no further than the 2018 FCPA enforcement actions to date for examples, all of which have...more

Foley & Lardner LLP

Anti-Bribery Compliance Meets Permits, Approvals and Licences in India

Foley & Lardner LLP on

Obtaining permissions, approvals and licences in India creates high risks for bribery on account of there being significant interaction between the company and government authorities. Originally published by IBA...more

Foley & Lardner LLP

Common FCPA Issues

Foley & Lardner LLP on

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

Morrison & Foerster LLP

Scottish Authorities Settle First Corporate Criminal Offence Under the Bribery Act

On 25 September 2015, prosecutors in Scotland announced the first application of the corporate offence of failing to prevent bribery under section 7 of the Bribery Act 2010. Due to self-reporting and extensive cooperation...more

Thomas Fox - Compliance Evangelist

Great Structures Week V – The Tacoma Narrow Bridge Failure and Preventing Failure in Your Compliance Program

I conclude my Great Structures Week with a focus on structural engineering failures: suspension bridges and the challenges of wind in their construction and maintenance. I am drawing these posts from The Great Courses...more

NAVEX

The State of Anti-Bribery & Corruption Programs: Key Trends and Takeaways from Recent Research Report

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Kroll and Compliance Week’s 2015 Anti-Bribery and Corruption Benchmarking Report, surveyed global compliance executives and revealed that, while compliance officers are aware of the risks of anti-bribery and corruption (ABC),...more

The Volkov Law Group

Managing And Minimizing Your Third-Party Risks

The Volkov Law Group on

Let’s start with a few basic assumptions – we all know that third parties are often the most significant risk for corruption. ...more

Thomas Fox - Compliance Evangelist

Kroll And Compliance Week Survey Anti-Bribery And Anti-Corruption

Not many people realize that the US has elected one president who served as a prisoner of war....more

Thomas Fox - Compliance Evangelist

From The Compact Model To The Luxury Model – Managing Your Third Party Risk

I am currently attending the Hanson Wade Oil and Gas Supply Chain Compliance conference in Houston. The event is excellent and the presentations have been ‘spot on’ for the nuts and bolts of how to do compliance. As the...more

The Volkov Law Group

Anti-Corruption High-Risk Audits

The Volkov Law Group on

The Justice Department and the SEC should be credited with promoting new compliance strategies and best practices. Whatever you may think about the DOJ/SEC FCPA enforcement program, they have pushed businesses to enhance...more

Thomas Fox - Compliance Evangelist

Distributors Should Be Analyzed As Any Other Third Party Representative in the Sales Chain

Ed. Note-David Simon is a partner at Foley and Lardner and Bill Athanas is a partner at Waller Lansden Dortch & Davis, LLP. Both have practices which include FCPA compliance. After my recent post on distributors under the...more

Thomas Fox - Compliance Evangelist

The Lilly FCPA Enforcement Action (Part III) Lessons Learned from Russia

This Part III is the final installment of my review of the Eli Lilly and Company (Lilly) FCPA enforcement action brought by the Securities and Exchange Commission (SEC). In this Part III, I will review the FCPA issues that...more

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