All FCPA articles – Page 16
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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.
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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.
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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.
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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.
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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.
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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 ...
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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.
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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.
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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 ...
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Blog
Compliance on the board
The Man From FCPA reveals what expertise is needed on the board of directors when your company is evaluated under the factors set out in Prong Three of the FCPA Pilot Program and the Evaluation of Corporate Compliance Programs.
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Blog
Board of directors’ compliance committee
It is incumbent that boards seek out and obtain sufficient information to fulfill their legal obligations and keep their company off the front page of the New York Times, Wall Street Journal, or Financial Times, just to name a few, to prevent serious reputational damage. A board compliance committee is ...
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Blog
Walmart sets aside $283M for FCPA resolution
Walmart-Stores has recorded an aggregate accrual of $283 million concerning the possible resolution with U.S. enforcement authorities of a longstanding Foreign Corrupt Practices Act case.
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Blog
FIFA trial and FCPA implications
From the requirements for an anonymous jury to the talk of “bag men” to the bandying about of some of the top names in sports broadcasting, the FIFA trials happeneing in New York City are proving to be a fascinating case.
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Blog
Two ex-SBM executives plead guilty in Petrobras bribery scheme
Two former executives at Dutch oil and gas services company SBM Offshore have pleaded guilty to conspiracy to violate the Foreign Corrupt Practices Act for their roles in a scheme to bribe foreign government officials in Brazil, Angola, and Equatorial Guinea.
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Blog
Individual prosecution in Rolls Royce corrupt case
For those who might have wondered if the Jeff Sessions’ Justice Department was going to enforce the Foreign Corrupt Practices Act, that question seems to have been answered in the affirmative.
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Blog
Rolls-Royce charges underscore trends in FCPA cases
The Department of Justice yesterday unsealed charges against five individuals for violations of the Foreign Corrupt Practices Act, underscoring two important trends in FCPA enforcement: a growing focus on individual liability, and the undeniable global nature of FCPA investigations today. The U.K. Serious Fraud Office today also issued an update ...
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Article
South Africa Gupta saga: A long list of compliance failures
Corruption allegations in South Africa have entangled some major international companies, highlighting due diligence, risk management, compliance, and audit control failures.
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Blog
Charles Cain named chief of FCPA Unit
The Securities and Exchange Commission has named Charles Cain chief of the Enforcement Division's national specialized Foreign Corrupt Practices Act Unit that focuses on violations of the anti-bribery provisions of the federal securities laws.
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Blog
Lesson from Alere enforcement action
The Man From FCPA explores the recent Alere Foreign Corrupt Practices Act enforcement action and the lessons brought forth.
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Blog
Baseball informs your compliance program
With the Houston Astros set to play in the 2017 World Series, the Man From FCPA is tuning in and—much to his surprise—learning that baseball has multiple lessons for the compliance professional.