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UK Bribery Act Internal Controls

The UK Bribery Act is an act of the Parliament of the United Kingdom enacted in 2010 to prevent, combat and penalize acts of bribery. The Bribery Act creates four offenses: 1) bribing another person 2) being... more +
The UK Bribery Act is an act of the Parliament of the United Kingdom enacted in 2010 to prevent, combat and penalize acts of bribery. The Bribery Act creates four offenses: 1) bribing another person 2) being bribed 3) bribing a foreign official 4) failure of a corporation to prevent bribery on its behalf. The Act provides for very stringent penalties and is considered one of the toughest pieces of anti-bribery legislation in the world.  less -
Foley & Lardner LLP

What Every Multinational Company Should Know About . . . Implementing an International Compliance Program (Part I)

Foley & Lardner LLP on

Record penalties for violations of U.S. regulations governing international conduct and transactions illustrate the risk of costly enforcement actions facing multinational companies. Yet, many multinational companies lack...more

WilmerHale

Bribery Act 2010: Ten Years On

WilmerHale on

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

Farewell to Rip Torn and Hello to Compliance Incentives

In the recently released Evaluation of Corporate Compliance Programs, 2019 Guidance by the Department of Justice, incentives are specifically identified in the section under “is your program effectively implemented?” The 2019...more

Mitratech Holdings, Inc

Global Voices: Beating Bribery – Best Practice in Ethics and Conduct on the Global Stage

One of the biggest headaches for companies conducting business overseas still remains bribery and corruption. The grey area of what is deemed a fair gift, meal or payment against what might be constituted a bribe is a...more

BCLP

Bribery Act review: economic crime and failure to prevent offences

BCLP on

The government published in May 2019 its responses to two Committee reports on financial crime. First,  the House of Commons Treasury Committee on 8 March 2019, published its report on “Economic Crime – Anti-money laundering...more

A&O Shearman

UK Jury Returns Guilty Verdict in First Contested Failure to Prevent Bribery Case

A&O Shearman on

The Crown Prosecution Service has confirmed that a refurbishment company, Skansen Interiors Limited, has been found guilty of failure to prevent bribery under section 7 of the Bribery Act 2010....more

Thomas Fox - Compliance Evangelist

Everything Compliance-Episode 12

Show Notes for Episode 12, the Summer Haze Edition The dog days of summer are on the horizon and the Houston Astros lead the major leagues in winning percentage. Coincidence that the US pulls out of the Paris Climate Accords...more

Thomas Fox - Compliance Evangelist

Rolls-Royce Global Enforcement Action: Part I

When most people across the globe think of Rolls-Royce, one word comes to mind – excellence. Yet that image largely relates to Rolls-Royce Limited, the automobile manufacturer, which was founded in 1909. Just a few years...more

Thomas Fox - Compliance Evangelist

Compliance Isn’t Going Away (and neither should you) – Part I

Yesterday I presented my views on why I believe that Foreign Corrupt Practices Act (FCPA) enforcement will continue under the new administration. Today, I want to begin a multi-part series (sorry I don’t know how long it will...more

A&O Shearman

Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA) / FCPA Digest - July 2016

A&O Shearman on

Shearman & Sterling’s bi-annual Trends & Patterns report provides insightful analysis of recent enforcement trends and patterns in the US, the UK, and elsewhere as well as helpful guidance on emerging best practices in FCPA...more

Thomas Fox - Compliance Evangelist

A COSO Look at Control Objectives

Brian Christensen, in an article in Corporate Compliance Insights (CCI) entitled “The Updated COSO Framework: Time for a Fresh Look at Internal Control”, said that the updated 2013 COSO Framework retained the core definition...more

The Volkov Law Group

Corruption Risks and Corporate Social Responsibility Spending

The Volkov Law Group on

Global companies have been embracing socially responsible spending projects to build stronger relationships with local communities. The idea makes a lot of sense and real projects can result in real benefits....more

The Volkov Law Group

Private Equity’s Corruption Risk Underbelly — Portfolio Companies

The Volkov Law Group on

FCPA enforcement will likely take a turn into the private equity industry. I know this is a regular claim by FCPA practitioners but we already can see the beginning of the trend. The “princeling” investigations are...more

Thomas Fox - Compliance Evangelist

Great Structures Week I: Vitruvius, the Brooklyn Bridge and Compliance

I recently completed a course from The Teaching Company, entitled “Understanding the World’s Greatest Structures: Science and Innovation from Antiquity to Modernity”, taught by Professor Stephen Ressler. It was a wonderful...more

Thomas Fox - Compliance Evangelist

The All-Star Game and Tone at the Top

Quite simply, any compliance program starts at the top and flows down throughout the company. Before you arrive at tone in the middle and bottom, it must start with a commitment at the top. All regulatory schemes for...more

Thomas Fox - Compliance Evangelist

Assessing Internal Compliance Controls – Part II

In this blog post I continue my exploration of how you should assess your compliance internal controls using the Committee of Sponsoring Organization of the Treadway Organization (COSO), publication “Internal Controls –...more

The Volkov Law Group

FCPA Predictions for 2015 (Part II of II)

The Volkov Law Group on

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

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