Posted inAnti-Bribery

Checking Up on GSK in China

When thinking through an FCPA risk assessment, one thing usually not considered adequately is a companyโ€™s sales culture. To see the consequences of that, one need look no further than GSKโ€™s corruption troubles in Chinaโ€”but, CW blogger Tom Fox writes, the reforms GSK has implemented with its sales force are just as telling, too. Our Man From FCPA has more inside.

Posted inAnti-Bribery

FIFA as โ€˜Victimโ€™: Your Response Matters When U.S. Government Pays Visit

Image:ย One lesson from the FIFA corruption scandal is that when the U.S. government comes knocking, it requires a serious and thoughtful response. So far, now-suspended FIFA president Sepp Blatter (left) has responded in a way decidedly not serious and thoughtful. Our anti-corruption blogger Tom Fox takes a closer look at how companies should behave when U.S. authorities visit, whether the company likes it or not. More inside.

Posted inAnti-Bribery

Yates and Caldwell Lay Out Their FCPA Expectations

Image:ย Deputy Attorney General Sally Yates (left) and Assistant Attorney General Leslie Caldwell talked last week about what they, and more importantly the Justice Department overall, expect from companies that want to receive as much credit as possible when embroiled in a Foreign Corrupt Practices Act investigation. What companies should do: voluntarily self-disclose, fully cooperate, timely and appropriate remediateโ€”is it that easy? CWโ€™s FCPA blogger Tom Fox explores further inside.

Posted inAnti-Bribery

Jumping on the VW Amnesty Microbus

Image:ย Last week Volkswagen offered amnesty to employees who admit any role they played in the emissions-testing scandal currently wracking the companyโ€”no doubt drawing upon the success Siemens had when it made a similar offer to employees during a 2006 Foreign Corrupt Practices Act investigation. Opinions differ on the move, but many seem to agree that VW employees would be wise to jump on the Amnesty Microbus sooner, rather than later. Our Man From FCPA Tom Fox has more inside.

Posted inAnti-Bribery

On Advertising and the FCPA

Image:ย When can advertising violate the FCPA? That might not be a question often on the minds of compliance officers. The ongoing FIFA corruption scandal, however, demonstrates that any expenditure going out of a corporation may well need to be considered from an anti-bribery angle. Tom Fox, our Man From FCPA, has more.

Posted inRegulatory Enforcement

Justice Dept. Boosts Its Game for Corporate Compliance Programs

The Justice Department has long talked about the need for companies to take compliance programs seriously. Now with its first-ever compliance counsel hired (she started this month), the department itself will be able to bring a more practiced eye to evaluating compliance programs. This week, columnist Tom Fox reviews what we know about the compliance counsel and how her hiring may change Justice Department views on your companyโ€™s compliance effort.

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