reported by the FCPA
Blog , Corruption
Currents in the Wall
Street Journal and numerous
others , on July 13, 2011, Armor Holdings Inc., entered into a
Non-Prosecution Agreement (NPA) with the Department of Justice (DOJ) to pay a
One of the areas which is universally listed as a
component of a best practices compliance policy under the Foreign
Corrupt Practices Act (FCPA), UK Bribery Act and OECD Good Practices is that of
a written compliance code. However this is not an area...
On April 8, 2011, the Wall Street
Journal (WSJ) reported that Johnson & Johnson settled certain charges
related to violations of the Foreign Corrupt Practices Act (FCPA) with the
Department of Justice (DOJ) and Securities and Exchange Commission...
We recently wrote, and provided a list of examples, Red
Flags in the anti-corruption, anti-bribery, anti-money laundering context and
in the area of international economic sanctions. As we indicated, we do
not believe that the mere presence of a Red...
I am attending the 2011
Global Ethics Summit this week in New York City. It is presented by Ethisphere and Thomson Reuters . This post will be first
of several based upon the comments of the panelists. In today's posting we will
discuss some of...
In a story in the D&O
Diary , entitled " More
Woes for Companies with Chinese Connections ", Kevin LaCroix discussed
the settlement reached by the entity SciClone Pharmaceuticals, and its
individual defendant directors and officers,...
In an article in the September issue of the ACC
Docket , entitled " Swarm Ethics ", author James Nortz discusses a
technique to improve decision making in "circumstances that present complex
moral questions" which he designates...
In an article in the most recent issue of the Houston
Business Journal, entitled " Putting a partner through too many changes
increases risk ", columnist Connie Barnaba discusses one of the risks often
overlooked in a mergers and acquisitions...
This article was reprinted with permission
from FCPA Professor
Citing to certain of my prior scholarship ( here and here ) and
other writings, and otherwise highlighting certain issues that have
been frequently highlighted on this site for a long...
We often write and speak on some of the lesson learned
from enforcement actions brought by the Department of Justice (DOJ) under the
Foreign Corrupt Practices Act (FCPA). We believe that companies can not only
learn from the mistakes of others in implementing...
In every crisis there is an opportunity. This was
presented, perhaps less starkly, in an article in the spring 2012 Issue of the MIT Sloan Management Review ,
entitled " Achieving
Successful Strategic Transformation " , by authors Gerry Johnson...
Last week I attended the 2012 Global Ethics Summit hosted
by Ethisphere. The first event was a conversation between Mark Mendelsohn and
Brackett Denniston, Senior Vice President and General Counsel of General
Electric (GE). They both had some interesting...
I often write about what I call Paul McNulty's three
maxims of a Foreign Corrupt Practices Act (FCPA) compliance program: 1) What
did you do to prevent it?; 2) What did you do to detect it?; and 3) What did
you do to remedy it? I had generally...
In an article published in the August 30, 2011 Wall Street Journal , entitled " Iran's
Hong Kong Shipping Shell Game ", Claudia Rosett reported on efforts by Iran
to reflag ships to companies with Hong Kong registries. While the focus...
The House Judiciary Committee will hold hearings Tuesday
on the Foreign Corrupt Practices Act. At this point the Witness List as set
forth on the Committee's website is as follows:
Former Attorney General...