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 […]
Anti-Bribery
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, […]
Posted inAnti-Bribery
The e-Discovery Challenges of an FCPA Investigation
Companies have enough of a hard time tracking all the information and data that could become part of a domestic lawsuit. Add a multinational component to the mix and the task becomes far more complex. There are cultural disparities and differences in technology platforms that need to be considered, and the miles between international units […]
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The New Whistleblower Threat: Other Companies
Ever since the Securities and Exchange Commission began offering hefty rewards in exchange for tips about corporate misconduct, compliance officers have had to worry that the first indication of wrongdoing could come from a knock on the door by the agency’s enforcement lawyers. Now they may have a whole new concern on their hands: companies […]
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Big Data Playing a Bigger Role in Fraud-Spotting
Ferreting out fraud is never easy. For years, compliance professionals have relied on the bravery of whistleblowers, the mis-steps of perpetrators, and a good amount of luck to uncover wrongdoing both inside and outside their companies. That may all be changing with the advent of the Big Data era. These days, high-powered analytic tools can […]
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Lost in Translation: How Language Is Complicating Global Compliance
Texas based medical device company Orthofix got lost in translation. The company’s $5.2 million agreement last month to settle Securities and Exchange Commission charges for violations of the Foreign Corrupt Practices Act can be traced, at least partly, to problems communicating the company’s policies to employees in non-English speaking units outside the United States. The […]
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Companies Entering Collective Pacts Not to Pay Bribes
Compliance executives from around the world increasingly are banding together as part of a concerted effort to tackle corruption risks in emerging markets. The thrust of such global movement is to share best practices to collectively reduce corruption within every industry, and also to provide a united front to dishonest government officials who are looking […]
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Companies Struggle to Manage Third-Party Corruption Risk
Corporate compliance departments are increasingly uneasy about their exposure to bribery risks, and many say they are still not up to snuff when it comes to policing third parties and eliminating facilitation payments. According to a recent study from Kroll Advisory Solutions, 69 percent of 139 compliance executives surveyed say their companies have either high […]
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Brad Pitt: The New Anti-Corruption Compliance Officer
Anti-corruption compliance efforts are rarely, if ever, as easy as a-b-c. However, these endeavors would be much easier and more effective if more companies understood—and deployed—their ABCs. “ABC” refers to anti-bribery and corruption analytics, which are statistical techniques that comb through massive amounts of data and sniff out unusual patterns, questionable transactions, and compliance risks […]
Posted inAnti-Bribery
Finding FCPA Violations in Employee Expense Reports
Travel and entertainment expenses have long been a haven for fraud and abuse. Lately, however, companies have shifted their worries to whether there may be evidence of bribery or corruption hiding in employee expense reports. As the crackdown by U.S. officials on compliance with the Foreign Corrupt Practices Act continues to intensify, companies have started […]
