All FCPA articles – Page 16
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Blog
Kinross and internal controls
There are some important lessons that can be garnered by CCOs when examining recent FCPA internal control violations made by Canadian gold and silver mining company Kinross.
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Blog
The continuous improvement cycle in compliance
There are two basic tools in the continuous improvement cycle for any best practices compliance program, auditing and monitoring. The Man From FCPA illustrates how to effectively accomplish both within your program.
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Of Saudi princes and gilded cages
If you have done business in Saudi Arabia or with wealthy Saudis over the past few years, now might be a very good time to review not only those business relationships, but also your FCPA compliance program, writes The Man From FCPA.
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Fresenius Medical Care reserves €200 million in FCPA case
Germany-based Fresenius Medical Care, a provider of dialysis products and services, has set aside €200 million concerning its ongoing settlement negotiations with the U.S. government regarding potential violations of the Foreign Corrupt Practices Act.
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Teradata FCPA probe ends without enforcement action
IT service management company Teradata will not be facing any enforcement action following an investigation into questionable gifts and travel expenses by one of its international subsidiaries doing business in Turkey.
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Facilitation payments under the FCPA
In addition to its restrictions, a key to FCPA compliance is accurately recording facilitation payments going forward. As with all things FCPA-related, the “document, document, document” mantra holds.
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Extortion policies under the FCPA
An extortion payment, while not a violation of the FCPA, should have its own set of policies and procedures that employees adhere to per the chief compliance officer.
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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.
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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.
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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.
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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.
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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.
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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.
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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 ...
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The three levels of due diligence
How to recognize and utilize each level of due diligence to fight corruption.
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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?
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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.
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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.
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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.
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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.