All FCPA articles – Page 15
-
Blog
Charitable entities and compliance
The stories of Plan International USA and of Oxfam make clear the need for robust compliance programs in a non-profit charity.
-
Blog
Continuous monitoring to continuous improvement
To continuously improve a compliance program, the compliance team should apply a consistent set of protocols, checks, and controls tailored to the company’s risks. Tom Fox offers some guidance on how to do just that.
-
Blog
The effects of corruption at home
Petrobras (of Operation Car Wash fame) will soon consider offers to sell a refinery located in Pasadena, bringing the effects of the FCPA home to the United States.
-
Blog
Using investigative findings as the basis of remediation
There is nothing like an internal whistleblower report about an FCPA violation to trigger the board of directors and senior management attention to the compliance function and the compliance program.
-
Blog
Did OSI Systems commit FCPA and securities trading violations?
OSI Systems said the SEC and Department of Justice have commenced investigations into potential violations of the Foreign Corrupt Practices Act, and also are investigating trading in the company’s securities.
-
Blog
Cobalt: SEC ends second FCPA probe
Cobalt International Energy disclosed in a securities filing this week that the SEC concluded its second investigation into potential violations of the Foreign Corrupt Practices Act related to the company’s operations in Angola and does not intend to bring an enforcement action.
-
Blog
South Africa reminds the FCPA covers political parties
For any company doing business in South Africa, all your contacts with the African National Congress have FCPA implications; This means all the investigations you might be performing for contracts with the South African government, anything associated with the Gupta family or state-owned enterprises, should be assessed for ANC contacts ...
-
Blog
The three levels of due diligence
How to recognize and utilize each level of due diligence to fight corruption.
-
Blog
What is a root cause analysis?
The Justice Department has mandated a root cause analysis should be performed for every incident rising to the level of a compliance violation. Is your team ready to do so?
-
Blog
The end of the compliance defense debate
Over the years, there has been a siren’s call for the addition of a compliance defense to the FCPA. It’s time to send the so-called “compliance defense” packing.
-
Article
How the FCPA withstands the test of time
Certain enforcement trends stemming from the Foreign Corrupt Practices Act will be with us for many years to come.
-
Article
Lessons from the FCPA corporate enforcement policy
The Department of Justice’s new FCPA Corporate Enforcement Policy offers valuable lessons for companies that are considering how best to address a potential FCPA violation.
-
Blog
Former president of transportation company indicted on bribery charges
The Department of Justice last week unsealed an indictment against a former co-president of a Maryland-based transportation company for his alleged role in a bribery scheme involving an official at a subsidiary of Russia’s State Atomic Energy Corporation.
-
Blog
Non-monetary and indirect cost of a FCPA investigation
The Man From FCPA recently spoke with Dan Chapman, CEO of Presyse Compliance, about his experience with the non-monetary costs and indirect costs of a major FCPA investigations.
-
Blog
Oh thank heaven?
Tom Fox explores the recent raids by agents from the U.S. Immigration and Customs Enforcement (ICE) of 7-Eleven stores across the country, looking for undocumented workers from an FCPA perspective.
-
Blog
The role of risk management in compliance
As compliance evolves and corporate compliance programs become more sophisticated, compliance is seen not as simply a legal prophylactic, but as a business process, writes The Man From FCPA.
-
Blog
More fallout from Och-Ziff corruption case
In an interesting turn of events, the Och-Ziff corruption case recently reared its head once again, following news that Michael Cohen—who once oversaw the company’s investments in Europe, the Middle East and Asia—is facing criminal charges of fraud and obstruction of justice, according to recently unsealed court documents.
-
Blog
The stunning Petrobras securities lawsuit settlement
In a stunning capitulation, Petrobras settled with U.S. investors for nearly $3bn in a class-action lawsuit as follow-on litigation to the long-standing corruption allegations against the company.
-
Blog
The desktop risk assessment
If you perform an annual Desktop Risk Assessment with a full worldwide risk assessment every two years, you should be in a good position to keep abreast of compliance issues that may change and need more or greater risk management.
-
Article
As the FCPA turns 40, compliance officers reflect on its impact
Dec. 19 marks the 40th anniversary of the Foreign Corrupt Practices Act, prompting compliance officers to take stock of the overall effect FCPA enforcement has had on anti-corruption compliance programs.