Corporate Use of Third-Party Artificial Intelligence (AI) Tools
One Month to More Effective Written Standards: Day 17 – Policies for Third-Parties
Third Party Observation in Patent Prosecution in China
Consumer Finance Monitor Podcast Episode: Recent Federal and State Debt Collection Developments
Thobekile Cynthia Khumalo on Third Party Due Diligence
Protecting Trade Secrets When Facing Lawsuits or Alternative Dispute Resolution Procedures
Education Data Privacy and Security Laws: Best Practices for School Districts
Episode 162 -- Jessica Sanderson on How to Conduct a Remote Third Party Audit
VIDEO: Update on Third Party Workers’ Compensation Settlements in Pennsylvania
Episode 120: Interview of NAVEX Global Third-Party Risk Officials: Chris Bailey and Stephen Gooding
Subro Sense Podcast - Unpacking Product Claims Against Amazon
Business Succession Planning: Strategies for the Transition
E17: Carpenter Decision Builds Up Privacy from #SCOTUS
Day 17 of One Month to More Effective Continuous Improvement-Financial Health Monitoring
Day 6 of One Month to More Effective Continuous Improvement-Data Analytics and the Monitoring of Third Parties
FCPA COMPLIANCE REPORT-EPISODE 337, JAMES GELLERT ON ASSESSING 3RD PARTY FINANCIAL HEALTH FOR COMPLIANCE
FCPA Compliance Report-Episode 274, Scott Lane on an holistic approach to third party management
FCPA Compliance and Ethics Report-Episode 169-the First Mailbag Issue
FCPA Compliance and Ethics Report-Episode 95-interview with Scott Killingsworth on Private to Private Compliance Solutions
FCPA Compliance and Ethics Report-Episode 88, Internal Controls for Third Parties Under the FCPA, Part I
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
A careful reading of the DOJ and SEC settlement documents for the SAP case will puzzle you. I know I am scratching my head trying to make sense of the whole picture here. There are a number of significant indicators of a...more
In our prior update (published November 29), we provided the first five steps in our twelve-step program for international compliance. These steps are intended to help companies identify international regulatory risk inherent...more
As every compliance practitioner is well aware, third-parties still present the highest risk under the FCPA. The DOJ 2023 ECCP devotes an entire prong to third-party management. It begins with the following: A well-designed...more
With all eyes turning to 2023, recent Department of Justice (DOJ) corporate enforcement policy changes and clarifications hint at what can be expected from the DOJ in the year ahead. In September, Deputy Attorney General...more
Deputy Attorney General (DAG) Lisa Monaco’s September 15, 2022, memorandum on revisions to the Department of Justice’s (DOJ) Corporate Enforcement Policies (the Monaco Memo) reflects that preservation of business...more
The DOJ has signaled that CEO and CCO certifications will become a staple of all corporate settlement agreements. Critics worry CEOs and CCOs face undue personal liability and argue it will dissuade CCOs from accepting the...more
The arduous process of FCPA compliance requires risk teams to digest and cross-reference a morass of information – from internal data analysis to human representatives collecting interviews on the ground. Diligence failures...more
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
The first step is to convert your company’s compliance risks into internal control objectives. The internal control objectives are then given to each business unit with instructions to develop controls, which meet the...more
The U.S. Department of Justice (DOJ) has issued an opinion letter (catalogued as FCPA Opinion No. 20-01) stating that it does not intend to take enforcement action under the Foreign Corrupt Practices Act (FCPA) against a...more
Global companies face extraordinary risks through their reliance on third-party agents, distributors, consultants and vendors/suppliers. Federal prosecutors and regulators have had a record year in FCPA and sanctions...more
Whether they are Joint Ventures (JVs), partnerships, franchises, team agreements, strategic alliances or one of the myriad types of business relationships a U.S. company can form outside the U.S., they present diverse risks...more
This week I am mining the guilty pleas of the former Unaoil Chief Executive Officer (CEO), Cyrus Ahsani, and former Chief Operations Officer (COO), Saman Ahsani, for what they might mean for Foreign Corrupt Practices Act...more
Nine years ago today, 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. It was...more
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
After a sidetrack into the ethical train wreck detailed by the SEC Cease and Desist Order re: KPMG yesterday, I am returning to the blog post series I am running based upon the New York Times (NYT) reporting by Alexandra...more
Continuous improvement can take many ways, shapes and forms. Typically, when it comes to third-party risks, a Chief Compliance Officer (CCO) or compliance professional will consider the ownership structure to see if there is...more
Recently, and without the fanfare that often accompanies new policy guidance regarding corporate fraud, the Fraud Section of the Department of Justice posted a document on its website entitled “Evaluation of Corporate...more
Without fanfare, on February 8 the Fraud Section of the Department of Justice (DOJ) published new corporate compliance guidance on its public website. The guidance is presented as a set of topics and questions, entitled...more
This week has evolved into an exploration of different types of compliance committees a company might employ to make their compliance function more effective. On Monday, together with Baker Hughes Incorporated (BHI) Chief...more
I hate to be the harbinger of bad news; that is against my nature; I am naturally an optimistic person. As I always say, there are solutions to every problem....more
I find myself quibbling with compliance terms – hyper focus on small issues is not a positive trait. I often urge clients and colleagues to focus on issue of more significance and leave the smaller ones for another day....more
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
Welcome to the third issue of Focus on China Compliance for 2015. According to the FCPA Blog’s October 2015 Corporate Investigations List, China leads the countries reported to be involved in FCPA investigations with 29...more