Posted inAnti-Bribery

Sweating the Small Stuff on Bribery and Facilitation Payments

Faced with a global crackdown on corruption, more companies are putting zero-tolerance policies in place for bribery. Eliminating small bribes and facilitation payments throughout the organization, however, can be a difficult undertaking. Part of the problem is that small payments are sometimes requested in urgent situations, in which employees are forced to make crucial judgments […]

Posted inAnti-Bribery

TI-U.K. Guide to Combat Small Bribes a ‘Must Read’

Small bribes can amount to big problems for companies, according to the U.K. arm of the anti-corruption group Transparency International, which published a guide on combating the issue this summer. The watchdog’s “Countering Small Bribes: Principles and good practice guidance for dealing with small bribes including facilitation payments” contains practical advice for companies on how […]

Posted inAnti-Bribery

Delaware’s Walmart Ruling Has Consequences Big and Small

Shareholder derivative actions are beginning to play a greater role in Foreign Corrupt Practices Act enforcement. They are also spurring some companies to make changes to their FCPA compliance programs. In 2011, for example, SciClone Pharmaceuticals settled a shareholder derivative action based on FCPA allegations in which it agreed to institute a wide-ranging anti-corruption compliance […]

Posted inAnti-Bribery

Banks Revisit AML Compliance Amid Push for Stricter Rules.

The government is warning banks to beef up compliance programs to defend against money laundering and related offenses. The push comes as proposed regulations trigger a shift from a flexible, risk-based approach to customer due diligence to a more prescriptive one that comes with hard-and-fast rules and thresholds. Earlier this month, the Treasury Department’s Financial […]

Posted inAnti-Bribery

Banks Revisit AML Compliance Amid Push for Stricter Rules

The government is warning banks to beef up compliance programs to defend against money laundering and related offenses. The push comes as proposed regulations trigger a shift from a flexible, risk-based approach to customer due diligence to a more prescriptive one that comes with hard-and-fast rules and thresholds. Earlier this month, the Treasury Department’s Financial […]

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