In my last post about Walmart’s compliance reforms, we looked at how Walmart built a centralized, independent compliance function and decided its 14 key responsibilities worldwide. Now let’s look at how the company set specific compliance objectives and focused on achieving them. Jorgensen started with the audit committee. In its 2013 proxy statement filed one […]
Anti-Bribery
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Qualcomm May Face FCPA Enforcement Action
Digital telecommunications maker Qualcomm disclosed this week in a Form 10-Q filing with the Securities and Exchange Commission that it could face an enforcement action for potential violations of the Foreign Corrupt Practices Act. On April 23, Qualcomm said it received a Wells Notice last month from the SEC, indicating that SEC staff made a […]
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Walmart Outlines Compliance Reforms (Part I)
For more than a year, the compliance community has wondered exactly how Walmart would revamp its ethics & compliance operations to recover from the black eye the company received when news broke of extensive bribery activity in Latin America and elsewhere. Well, now we’re getting some answers. This week Walmart filed its annual proxy statement, […]
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Managing Third-Party Corruption Risks in Decentralized Companies
Earlier this month, tech giant Hewlett-Packard announced a $108 million agreement with the Department of Justice to settle charges that it violated the Foreign Corrupt Practices Act. The charges centered on the conduct of H-P affiliates in Russia, Poland, and Mexico, and they highlight a trend at the center of many recent FCPA cases: The […]
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FinCEN Could Fine Former MoneyGram Compliance Officer $5 Million for AML Compliance Lapses
The Treasury Department’s Financial Crimes Enforcement Network reportedly notified a former chief compliance officer of MoneyGram International that he could be fined up to $5 million for compliance failures that resulted in a widespread money-laundering fraud scheme. FinCEN sent a letter several months ago to Thomas Haider, former chief compliance officer at MoneyGram, notifying him […]
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Technology Consortium Develops Anti-Bribery Tool
The Global Technology Distribution Council, an industry consortium representing technology distributors, has launched an anti-bribery and anti-corruption (AB/AC) due diligence platform. The platform, developed in conjunction with Hiperos and Thomson Reuters, will be delivered as a managed network to both GTDC members and other non-member technology firms. The GTDC AB/AC platform combines processes and best practices developed […]
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Anti-Corruption Enforcement Widens Nets to More Industries
Global regulators are looking beyond the usual suspects for potential violations of bribery and corruption laws. While oil, gas, and mining companies face more charges of foreign and domestic bribery than any other industry in the world, according to a new global anti-corruption report, corruption enforcement actions are quickly piling up in other industries too, […]
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New Leadership, Same Priorities for the DoJ’s Criminal Division
As Leslie Caldwell awaits Senate confirmation to become assistant attorney general and the new chief of the U.S. Department of Justice’s Criminal Division, many are wondering what the transition will mean for the agency’s enforcement priorities. During the Obama Administration, the Criminal Division has pursued aggressive enforcement of violations of the Foreign Corrupt Practices Act, […]
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In Praise of FCPA Opinion Releases
One of the least-read sections of the U.S. Foreign Corrupt Practices Act is the section entitled, “Foreign Corrupt Practices Act Opinion Procedure.” This section allows companies to seek an opinion from the Department of Justice “as to whether certain specified, prospective—not hypothetical—conduct conforms” to the Justice Department’s current enforcement policy on the FCPA. It is […]
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H-P to Pay $108 Million for FCPA Violations
Hewlett-Packard today agreed to pay a total of $108 million to the Securities and Exchange Commission to settle civil and criminal charges over violations of the Foreign Corrupt Practices Act. On April 9, H-P agreed to pay $29 million in disgorgement, including $26.4 million to the SEC, and $2.5 million to satisfy an IRS forfeiture […]
