All FCPA articles – Page 13
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Blog
Asking questions about your third-party process
When regulators come knocking, it’s important to have the right protocols in place. Knowing what questions to ask can be a big help to companies when implementing a third-party due diligence process.
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No piling on requires global disclosure and cooperation
To receive the benefits of no piling on, companies must fully disclose their conduct and cooperate with regulators across the globe.
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Condos, corruption, and compliance
While President Trump promised condos in North Korea as a part of his negotiations with North Korean Supreme Leader Kim Jung Un, it doesn’t mean companies will have an easy time doing business in the country, which ranked as “highly corrupt,” on the 2017 Transparency International Corruption Perceptions Index.
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What is due diligence?
Due diligence is key to getting your third-party risk management program off the ground.
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Business justification for the use of third parties
Why is business justification for third parties so important? With the Department of Justice, Securities and Exchange Commission, and Internal Revenue Service all seeking such justification, companies should definitely make it part of the compliance process.
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Best practices: Hiring a business sponsor for third-party relationships
A significant piece of the compliance regime is overseeing third-party business relationships, and the best way to keep them on track is to employ the business sponsor.
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Executives behaving badly—at what cost?
FCPA violations from SocGen and Legg Mason may point to a new trend of holding the C-Suite accountable, but will voluntary resignations be seen as enough of a penalty?
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Credit Suisse to pay $47M in FCPA fines over hiring practices
Credit Suisse has become the latest financial institution to pay a penalty—to the tune of $47 million—and enter a non-prosecution agreement with the Department of Justice concerning questionable hiring practices in the Asia Pacific region.
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Legg Mason to pay $64.2M in FCPA case
Investment management firm Legg Mason entered a non-prosecution agreement and agreed to pay $64.2 million to resolve an investigation into violations of the Foreign Corrupt Practices Act concerning Legg Mason’s participation in a Libyan bribery scheme, the Department of Justice announced.
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SocGen to pay $860M in FCPA and LIBOR case
French banking group Société Générale and its wholly owned subsidiary, SGA Société Générale Acceptance, will pay a combined total penalty of more than $860 million to resolve charges with criminal authorities in the United States and France, the Department of Justice announced June 4.
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Legg Mason accrues $67M charge to earnings for FCPA matter
U.S. investment management firm Legg Mason disclosed in a securities filing on May 30 that it expects to soon complete negotiations with both the U.S. Department of Justice and the SEC to resolve a Foreign Corrupt Practices Act investigation.
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ArticleDeputy Attorney General Rod Rosenstein keynote: The value of compliance
Deputy Attorney General Rod Rosenstein kicked off Compliance Week 2018 in Washington D.C. on Monday, speaking candidly about compliance program effectiveness, the FCPA Corporate Enforcement Policy, the newly announced Justice Department coordination policy, and much more.
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ArticleD&B shows the right way to handle an FCPA probe
The D&B enforcement action should be studied by every compliance practitioner for tips on preventing an FCPA issue and what to do if you find one.
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ArticleExperts spotlight trends in FCPA self-disclosures and enforcement
Current and former enforcement officials took part in a candid debate last week about the real-world implications of recent pronouncements made by the Department of Justice and how directors and officers are responding.
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Trump lawyer’s woes provide lesson for compliance officers
New accusations against one of President Trump’s lawyers should prompt savvy compliance and risk officers to pursue a reinvigorated strategy for Bank Secrecy Act procedures and anti-corruption efforts.
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Vantage Drilling reaches ‘agreement in principle’ with SEC in FCPA case
Offshore drilling contractor Vantage Drilling Co. has “reached an agreement in principle” with the Securities and Exchange Commission regarding a previously disclosed investigation into potential violations of the Foreign Corrupt Practices Act.
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ArticleFCPA: An act of punitive moralism
Does the FCPA overstep the bounds of federal lawmaking in various ways? Cato Institute constitutional expert Walter Olson explores.
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ArticleFCPA: Sets a high bar for compliance
The FCPA has made some positive contributions to compliance programs over the past decade, writes compliance attorney James Koukios of Morrison Foerster.
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Autonomy verdict and FCPA defenses
A recent case involving Autonomy and Hewlett-Packard shows that it is not the bribe receiver’s conduct but the bribe payor’s conduct that matters.
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Learning lessons from FCPA enforcement actions
Two FCPA enforcement actions against Panasonic and Hewlett-Packard Mexico are good reading for the compliance practitioner and offer lessons in stamping out fraud.