All FCPA articles – Page 16
-
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.
-
Blog
Compliance in an economic downturn
In an economic downturn, there are two increasing compliance risks for companies that could make them in conflict with the 2012 FCPA enforcement guidance: (1) They eliminate compliance personnel in a cost-cutting attempt; (2) They neglect to invest monies needed to enhance monitoring or other mechanisms.
-
Blog
Mapping your internal compliance controls
By mapping out the internal controls your company has in place to the indicia of the FCPA Enforcement Guidance’s Ten Hallmarks of an Effective Compliance Program and the 2013 COSO Internal Controls Framework, your company can ascertain what it has and what needs to be implemented.
-
Blog
To operationalize compliance, pick up the phone
Following compliance policies and procedures is always important but to have a live person to answer questions or walk a non-compliance person through the process is a must.
-
Blog
The Holy Grail of compliance
A recent academic paper discusses companies’ progress in having the “Holy Grail of compliance,” the ability to demonstrate a positive return on investment (ROI) for your compliance program.
-
Blog
Best practices under the new FCPA Enforcement Policy
The Justice Department’s new Foreign Corrupt Practices Act Corporate Enforcement Policy once again makes the importance of a best practices compliance program even more critical.
-
Blog
SBM Offshore to pay $238M to resolve FCPA case
Dutch oil and gas services company SBM Offshore, and its wholly owned U.S. subsidiary SBM Offshore USA, will pay a criminal penalty of $238 million in connection with schemes involving the bribery of foreign officials in Brazil, Angola, Equatorial Guinea, Kazakhstan, and Iraq in violation of the Foreign Corrupt Practices ...
-
Blog
The compliance oversight committee
Installing a compliance oversight review committee is a crucial step that should be employed by companies as added protection against any type of compliance and ethics violations that could slip through the cracks and become much bigger problems down the road.
-
Blog
The regional compliance committee
The regional compliance officer adds a dimension not often seen or even discussed in the compliance profession, offering oversight of the compliance monitoring, reviewing, assessing, and recommending that is deemed necessary to the compliance function.
-
Blog
Saudi corruption crackdown—uncharted waters in the desert
What does the corruption crackdown in Saudi Arabia mean for investors? Is it positive for the Kingdom of Saudi Arabia in terms of investment dollars? Should investors run toward the Kingdom now or should they shy their investment dollars away? These and many other questions are being debated now. Both ...