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

What global anti-corruption compliance trends are on the OECD's radar?
Posted on 04-09-2019 by Lisa Thompson

This year is the 20th anniversary of the implementation of the OECD’s Anti-Bribery Convention. So, we went to Paris to meet Patrick Moulette, Head of the OECD Anti-Corruption Division. He explained that the global spread of negotiated settlements, particularly Deferred Prosecution Agreements, prompted... 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

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