Posted inAnti-Bribery

Walmart, in Damage Control Mode, Appoints Global FCPA Head

Walmart shifted into full damage-control mode, following allegations of a massive bribery and corruption campaign at its Mexico operations and an attempt to conceal payments to foreign officials, which first surfaced this weekend in a New York Times report. Yesterday Walmart announced that it was appointing a global FCPA compliance officer position. This position, which […]

Posted inAnti-Bribery

Targeting the Demand for Facilitation Payments

A consortium of compliance executives primarily from the energy industry is taking aim at one of the most vexing headaches businesses face today: facilitation payments. Facilitation paymentsโ€”more commonly called โ€œgrease paymentsโ€โ€”are small sums given to foreign officials to expedite normal business transactions, such as clearing goods through customs. They differ from bribes, which are typically […]

Posted inAnti-Bribery

Anti-Corruption Programs Enable Business Agility

One of the most frequently asked questions I hear about managยญing corruption risk demonstrates the compliance profession’s passion for benchmarking: โ€œWhat do companies with the best anti-corruption programs do difยญferently?โ€ The answer I give does not offer details about process or technology, at least not directly; instead, it boils down to philosoยญphy and vision. Compliance, […]

Posted inAnti-Bribery

The Dos and Don’ts of Corporate Hospitality

Rigorous enforcement activity against those who run afoul of the Foreign Corrupt Practices Act is apparently causing some compliance executives to second-guess even routine compliance decisions on corporate hospitality. That’s what many in the compliance community make of the Justice Department’s first FCPA advisory opinion release of 2011, which reiterates two nearly identical opinion releases […]

Posted inAnti-Bribery

Canada Takes Landmark Anti-Bribery Enforcement Action

Amid mounting international pressure to toughen its anti-corruption efforts, Canadian authorities have rendered their first significant conviction under Canada’s Corruption of Foreign Public Officials Act since its passage in 1999, a harbinger of more enforcement activity to come. โ€œIt’s been relatively quiet until now,โ€ says John Boscariol of law firm McCarthy Tรฉtrault in Toronto. โ€œI […]

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