How to message with due diligence
Posted on 05-06-2019 by Lisa Thompson

In March, the U.S. Department of Justice (DOJ) issued revised guidance for the Foreign Corrupt Practices Act’s (FCPA) Corporate Enforcement Policy (CEP) concerning the adoption of rules and regulations around the use of ephemeral messaging platforms, such as Snapchat, WeChat or Telegram for business... Read More

Frontline compliance requires expert juggling
Posted on 04-18-2019 by Lisa Thompson

There’s no room for clowning about when it comes to risk management and maintaining the integrity of international business. According to records of ancient Chinese history, the armies of the Chu and Song states were facing each other in readiness for battle in 630 BC when a Chu warrior, Xiong... Read More

Weighing risk and opportunity in Latin America
Posted on 01-16-2019 by Lisa Thompson

Despite recent Foreign Corrupt Practices Act (FCPA) enforcement actions, there are signs of more positive engagement with governance and compliance in Latin America. Emerging markets offer attractive opportunities for investors, but businesses aiming to capitalize will need to prioritize robust due diligence... Read More

Enter the ninja: A disciplined approach to defeat regulatory risk
Posted on 12-05-2018 by Lisa Thompson

Forget about the turtles. Today is International Ninja Day, but what we’re on about has more to do with regulatory risk than teenagers or (as far as we know) mutants. Why does International Ninja Day make us think ‘compliance program’? International Ninja Day was the brainchild of... Read More

A new No. 1: Petrobras agrees to biggest FCPA settlement
Posted on 10-05-2018 by Lisa Thompson

Petrobras has reached a $1.78 billion settlement with the DOJ and SEC over bribes to politicians and political parties in Brazil. This is the first time an enforcement action over FCPA violations has exceeded a billion dollars. The amount is bigger than the nearest two settlements combined, and the case... Read More

FCPA Corporate Enforcement Policy extended to M&A
Posted on 09-17-2018 by Lisa Thompson

The U.S. Corporate Enforcement Policy, which incentivises companies to self-disclose bribery and corruption when they come across it, now applies to U.S. companies which are merging with or acquiring foreign companies. That’s according to a recent speech by a senior official at the Department of... Read More

Why the Energy Sector Needs Better Due Diligence & Risk Monitoring
Posted on 08-23-2018 by Lisa Thompson

No industry is impervious to bribery and corruption risk, but companies linked to energy industries, in particular, face elevated risks in order to reap the equally-high rewards. It’s a topic we’ve touched on in blog posts on Unaoil and Petrobras . But anti-bribery and corruption regulations... Read More

Why Pharma & Biomed Companies’ Risk Analysis Processes are Due for a Check-Up
Posted on 07-18-2018 by Lisa Thompson

Just three years ago, Teva Pharmaceuticals, a drug-maker in Israel, disclosed to both the U.S. Securities & Exchange Commission and the U.S. Department of Justice that an on-going internal probe had revealed possible violations of the Foreign Corrupt Practices Act (FCPA) and/or local laws. Ultimately... Read More