Posted inAnti-Bribery

Yates and Caldwell Lay Out Their FCPA Expectations

Image: 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 remediate—is it that easy? CW’s FCPA blogger Tom Fox explores further inside.

Posted inAnti-Bribery

Jumping on the VW Amnesty Microbus

Image: Last week Volkswagen offered amnesty to employees who admit any role they played in the emissions-testing scandal currently wracking the company—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: 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 company’s compliance effort.

Posted inAnti-Bribery

Europe and Petrobras—What Has a Car Wash Wrought?

Image: The scope of the Petrobras corruption scandal is literally worldwide. Now, reports the Financial Times,  Rolls Royce has become embroiled in the Brazilian national energy company’s “Operation Car Wash” snafu (dubbed so because the investigation literally started with a car wash), and is currently under investigation by the British Serious Fraud Office for bribery. Now is the time for European chief compliance officers doing business in Brazil to learn from the scandal and, hopefully, come out ahead, says CW FCPA blogger Tom Fox. More of his thoughts inside.

Posted inAnti-Bribery

The UN, Corruption, and Internal Investigations

Image: Another corrupt scandal hit the United Nations recently. The claim was made that a former General Assembly president had engaged in receiving bribes and other corruption from a Chinese businessman (and perhaps others). Other than yet another embarrassment for the United Nations, the allegations are nothing unusual so far. What was was the response by the United Nations. The Man From FCPA, Tom Fox, has more.

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