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Episode #12, Part I of This Week in FCPA (Audio Version)
Posted on 18 Jul 2011 by Howard Sklar & Thomas Fox

Apologies for the technical issues last week. They recurred, but I was able to salvage the intact audio for part I of episode #12. We’ll post part II Monday night. Show notes: 1. Rehashing the opinion release from last week, with a surprising... Read More

Tags: FCPA

This Week in FCPA Episode #12, Part 2
Posted on 20 Jul 2011 by Howard Sklar & Thomas Fox

Topics discussed: 1. More on News Corp. 2. Haiti Telecom case 3. Armor Holdings 4. Letter to the SEC from Sen. Crapo 5. Opening up a whistleblower practice 6. Is AML coming to Private Equity, and what does that mean. (Please visit the site to... Read More

Tags: FCPA

This Week in FCPA Episode # 16
Posted on 12 Sep 2011 by Howard Sklar & Thomas Fox

Not a single technical issue for this one: no multiple-part episode because my system shut down, no nothing. Just the show. Topics: 1. Haiti Telecom: it's an SOE! No, it's not! Yes, it is! 2. ICE doesn't get en banc review. And Howard... Read More

Tags: FCPA

Four Steps to Resolving Your FCPA Compliance Issues
Posted on 30 Jun 2011 by Thomas Fox

As regular readers of this blog know I often cite the three maxims of Paul McNutly as the basis for a good compliance program. They are the questions that the government will ask when they come knocking: (1) What did you do to prevent it?; (2) What did... Read More

Send Lawyers, Guns and Money - Some Steps Law Firms Should Consider
Posted on 15 Oct 2012 by Thomas Fox

One of my favorite lawyer songs is the Warren Zevon classic " Lawyers, Guns and Money ". I was reminded of that song when I sat on a panel on Wednesday with Dan Chapman and Mike Volkov, where we discussed recent enforcement actions and due diligence... Read More

NFL Replacement Referees-the Lessons of Training Temporary Employees
Posted on 10 Oct 2012 by Thomas Fox

The short autumn of our discontent is over as the United States has ended one of its greatest national convolutions of recent memory. Am I speaking of the attack on the US Consulate in Libya; the current stalemate of US politics and the Presidential race... Read More

The Mini Cooper and Project Execution in Compliance
Posted on 27 Aug 2015 by Thomas Fox

The price of oil hovers near $40 per barrel. There are all manner of responses suggested to this drop from nearly $100 per barrel just a short time ago. Yet the price of oil has long been much more than a political conversation, sometimes it leads to... Read More

Front-Line Interview Episode 1: Alison Taylor, How Organizations Impact Corruption
Posted on 27 Aug 2015 by RBistrong

(Please visit the site to view this video) In the launch of a new video series, Front-Line Interviews, I engage with Alison Taylor, Director of Energy and Extractives at BSR (Business for Social Responsibility). I first became aware of Alison’s... Read More

Friday FCPA Roundup for Week Ending Dec. 6
Posted on 6 Dec 2013 by Mike Koehler

This article was reprinted with permission from FCPA Professor Looking for talent … got talent, the DOJ is sued, the Corruption Perceptions Index, a pulse on FCPA Inc., and for the reading stack. It’s all here in the Friday roundup. ... Read More

Secretary of State Kerry Gets It Right
Posted on 11 Nov 2013 by Mike Koehler

This article was reprinted with permission from FCPA Professor Secretary of State John Kerry got it right recently when he linked trade barriers and other distortions to – among other things – corruption. Speaking to American Chamber... Read More

Professor Koehler Files Amicus Brief Urging Supreme Court To Hear “Foreign Official” Challenge
Posted on 18 Sep 2014 by Mike Koehler

This article was reprinted with permission from FCPA Professor This previous post highlighted the petition for certiorari filed in the Supreme Court requesting the Court hear U.S. v. Esquenazi (the recent 11th Circuit decision of first impression in... Read More

This Week in FCPA Episode # 13
Posted on 25 Jul 2011 by Howard Sklar & Thomas Fox

Lucky Episode #13! 1. News Corp. 2. Willis 3. McPublishing Company (Please visit the site to view this video) Read More

Tags: news , FCPA

SEC-BNY Mellon Settle FCPA Charges Tied to Hiring Relatives of Officials
Posted on 19 Aug 2015 by Thomas O. Gorman

The SEC has been investigating sovereign wealth funds and issues relating to the hiring of friends and family of foreign officials for some time. Now it has filed a settled action centered on both of those issues which contains a cautionary note for those... Read More

End of the Annual Compliance and Ethics Training ‘Flea Dip’
Posted on 10 Aug 2011 by Thomas Fox

In an article in the July/August edition of the ACC Docket entitled " Rethinking the Annual Compliance and Ethics Flea Dip ", author James Nortz discusses the annual compliance and ethics training program that most US company's employees... Read More

Bank of New York Mellon Settles FCPA Charges Regarding Internships for Relatives of Sovereign Wealth Fund Officials
Posted on 25 Aug 2015 by Cadwalader, Wickersham & Taft LLP

On August 18, 2015, the Securities and Exchange Commission (“SEC”) announced that the Bank of New York Mellon Corporation (“BNY Mellon”) had agreed to settle administrative charges that it violated the Foreign Corrupt Practices... Read More