Brazil and Anti-Corruption Legislation

As one of the world's largest energy producing countries, many US companies have subsidiaries in Brazil, which are subject to the Foreign Corrupt Practices Act (FCPA). Most of these companies have translated versions of the US FCPA compliance program. Such translations often disregard the size...

The United Nations Convention against Corruption: A New Focus?-Part I

Ed. Note-today I begin a two-part series on the attempts to invoke the United Nations Convention against Corruption in the FCPA context. This article is written jointly with my colleague Mary Shaddock Jones. In an article published in the August 21, 2011 edition of the Sunday Nigerian Tribune...

The United Nations Convention against Corruption: A New Focus?-Part II

Ed. Note-Yesterday we began a two part series on the attempt by the NGO SERAP to invoke the United Nations Convention against Corruption on certain FCPA related matters. Today we conclude our series. This article is written jointly with my colleague, Mary Shaddock Jones. We have kept the article's...

Transparency International Guidance on Anti-Corruption and Anti-Bribery Due Diligence for M&A Transactions – Part I

Transparency International (TI) recently released, in draft form for consultation, a White Paper entitled " Anti-Bribery Guidance for Transactions ." Although this version was preliminary draft, available for a commentary period and the final version is to be released later in October,...

Wolfsberg Anti-Corruption Guidance

In a recently released White Paper by the Wolfsberg Group, entitled " Wolfsberg Anti-Corruption Guidance " , a group of internal banks, together with Transparency Internal and the Basel Institute on Governance, issued guidance on anti-corruption and anti-bribery procedures which financial...

The Worst Conflict of Interest Move of All-Time (at Least Since Enron)

Last week, I observed one of the worst actions by a major league sports commissioner in my lifetime. Not the worst, as I will give that "worst award for a decision made by a sports commissioner in my lifetime", to either of two Baseball Commissioners; Ford Frick, for the * next to Roger...

OCEG Illustrated Series: Managing Corruption Risks

How do you move off dead center? That was a question posed by my colleague Mary Jones in a recent guest blog post. She gave several concrete steps in answer to her own question. This question was further explored in the January issue of the Compliance Week magazine which began a six-part " Anti...

Earl Scruggs: Banjo, Bluegrass and the Fight against Corruption and Bribery

Last Thursday, Earl Scruggs died. He was one of the musician's most responsible for my development in learning about, and appreciating, different styles of music. For musicians, he basically invented and then popularized the 3 finger picking style on the 5 string banjo. For popular culture, he...

OCEG on Third Party Anti-Corruption Due Diligence

My grandfather was a comic book collector. He collected all kinds and types of comics, from super-heroes to the Archie series. One of the series that he collected that I still think about from time-to-time was Classics Illustrated. Classics Illustrated was a comic book series featuring adaptations...

The Five Essential Elements of a Corporate Compliance Program – Part II

Yesterday, Stephen Martin and I co-presented at a Foreign Corrupt Practices Act (FCPA) event hosted by Kreller. If you are in or near Chicago, I hope that you can join us for this presentation. The title of our presentation is " Anti-Corruption/FCPA Developments & Best Practices " and we...

Kroll and Compliance Week Survey Anti-Bribery and Anti-Corruption

Not many people realize that the US has elected one president who served as a prisoner of war. That man was Andrew Jackson, who was captured by the British during the Revolutionary War. Now, can you name the American President who killed another man in a duel? If you guessed Andrew Jackson you are...