Companies that do business in Russia know that the corruption risks there are massive. Some new laws in Russia could help stem the threat, but anti-bribery law experts say they will believe it when they see it. Russia has long been viewed as a bastion for corrupt officials on the take. Transparency International, which issues […]
Anti-Bribery
Posted inAnti-Bribery
Inside FCPA Guidance: What to Expect Next
Just in time for the season of giving, the Department of Justice and the Securities and Exchange Commission have doled out a much-anticipated gift of their own: a resource guide to the Foreign Corrupt Practice Act. By essentially unifying into a single document what previously existed as a piecemeal collection of informal opinions and case […]
Posted inAnti-Bribery
Fostering a Unified, Ethical, and Global Corporate Culture
Building an ethical corporate culture can be daunting under even the best of circumstances. Add to the mix a workforce located in multiple countries, each with its own culture, language, and legal system, and the challenges are magnified. Yet, companies can’t ignore these obstacles, given the increasingly global economy. In 2011, nearly half (46 percent) […]
Posted inAnti-Bribery
U.K. Provides New Guidance on Bribery Act Compliance
Britain’s Serious Fraud Office announced tough-talking new policies earlier this month on how it will enforce its new Bribery Act. The agency says it is now taking a harder line on facilitation payments and corporate hospitality, and providing fewer leniencies for self-reporting. Mostly the changes are a matter of tone rather than substance, lawyers say. […]
Posted inAnti-Bribery
Sharpening Third-Party Risk Mitigation
Never has third-party risk management been as high a priority as it is in today’s stringent anti-corruption enforcement environment. Yet, many companies still aren’t up to snuff when it comes to refining the processes used to mitigate third-party risks. They are in a “relative state of paralysis,” says Kenneth Kurtz, chief executive officer of Steele […]
Posted inAnti-Bribery
SFO Issues Revised Bribery Guidance
Britain’s Serious Fraud Office has published new guidance today that includes tougher standards for when a company may be prosecuted under the U.K. Bribery Act. The guidance issued Oct. 9 covers the SFO’s latest enforcement approach toward facilitation payments, gifts and hospitality, and self-reporting. SFO Director David Green said the latest changes have been made […]
Posted inAnti-Bribery
Building the Foundation for a Unified GRC Function
Building a compliance program from the ground up from a well-conceived blueprint is a luxury few compliance professionals enjoy. Most companies already have some initiatives in place—an environmental, health, and safety program or anti-money laundering policies, for example. While the existence of such programs is not necessarily bad in itself, building on to them can […]
Posted inAnti-Bribery
Tyco in Hot Water Once Again After FCPA Settlement
Anyone searching for some broader context to understand how Tyco International lurched into yet another bribery scandal—the third major misconduct meltdown to hit Tyco or one of its spin-off companies since 2002—would do well to ponder one of the most famous lines from The Godfather. “Just when I thought I was out,” crime boss Michael […]
Posted inAnti-Bribery
Elements of Effective Compliance
There’s no shortage of guidance from regulators around the world on what a good compliance program should entail. In theory, documents such as the U.S. Federal Sentencing Guidelines and many others should help compliance departments design robust, sensible programs. In practice, however, the proliferation of such guidance can make the job daunting and confusing. The […]
Posted inAnti-Bribery
Anti-Bribery Enforcement on the Rise
Tougher enforcement of anti-bribery laws around the world has resulted in more companies facing prosecutions, according to a new report from anti-corruption watchdog Transparency International. Countries involved in the Organization of Economic Cooperation and Development’s Anti-Bribery Convention, a coalition established to fight global corruption, added a total number of 144 open cases of criminal prosecutions, […]
