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...
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
In an article published in the August 21, 2011 edition of
the Sunday Nigerian Tribune...
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
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,...
Transparency International (TI) recently released a
consultation draft of its White Paper entitled " Anti-Bribery Guidance for
Transactions ". In Part I we discussed the risks to companies involved in
international mergers and acquisitions. The TI White Paper notes that
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...
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...
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...
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...
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
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...
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...