Corporate

Recent Posts

Isn’t It Ironic, Don’t You Think?
Posted on 19 Sep 2012 by Mike Koehler

This article was reprinted with permission from FCPA Professor [Proper citation to Alanis Morissette is in order, this song makes for good background music as well for this post] This post has been in the works for some time, but with the recent... Read More

Tags: corruption

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

The Biomet SEC Complaint: Lessons for Internal Audit
Posted on 28 Mar 2012 by Thomas Fox

On March 26, 2012, both the Securities and Exchange Commission (SEC) and the Department of Justice (DOJ) announced the resolution of enforcement actions against Biomet Inc. a US entity, which manufactures and sells global medical devices around the... Read More

FCPA Enforcement: Why the Increase between the First 25 Years and the Last 5?
Posted on 11 Mar 2011 by Thomas Fox

On Thursday, March 10, the World Compliance Tour came to Houston. It featured presentations by Michael Volkov, of the law firm of Mayer Brown; Ryan Morgan, of World Compliance; and Richard Cassin, author of the FCPA Blog . The session was very informative... Read More

Corruption Is Bad, But What Is It?
Posted on 17 Dec 2014 by Mike Koehler

This article was reprinted with permission from FCPA Professor Last week, International Anti-Corruption Day was recognized. This short White House press release used the word “corruption” 13 times. DOJ Assistant Attorney General Leslie... Read More

The Sussex Vampyre and the ADM FCPA Settlement
Posted on 31 Jan 2014 by Thomas Fox

Today I want to use the story of The Sussex Vampyre as the starting point for an inquiry into the recent Archer-Daniels-Midland Corp (ADM) Foreign Corrupt Practices Act (FCPA) enforcement action. In the story, Holmes receives a letter from Robert Ferguson... Read More

Fast and Furious: Corruption in Brazil and Upcoming World Cup and Olympics
Posted on 14 Nov 2011 by Thomas Fox

I recently saw the latest installment of the Fast and Furious franchise, entitled "Fast Five". In this installment, Vin Diesel as Dominic Toretto and Paul Walker as Brian O'Conner led a team which steals over $100 million from a Brazilian... Read More

Scalping Tickets and the Use of Fake Invoices in China
Posted on 7 Aug 2013 by Thomas Fox

I long ago learned that there is no such thing as a ‘sold out event’; as the scalping of and for tickets to sports events is a long and time honored tradition. However with the advent of such websites as StubHub.com, it certainly has never... Read More

GSK Convicted – We Are Really, Really Sorry We Paid Bribes (and Got Caught)
Posted on 22 Sep 2014 by Thomas Fox

“GSK plc sincerely apologies to the Chinese patients, doctors and hospitals, and the Chinese Government and the Chinese people.” With those words, the British pharmaceutical giant GlaxoSmithKline (GSK) PLC was convicted in a secret trial... Read More

Show Me the Money – Employee Compensation to Prevent Bribery and Corruption
Posted on 26 Jul 2013 by Thomas Fox

The GlaxoSmithKline PLC (GSK) matter continues to resonate across the compliance world. Ongoing news releases by the company and announcements from named and un-named sources on the underlying facts continue to generate press worldwide. But there are... Read More

Billy the Kid Begins and the GSK China Verdict
Posted on 24 Sep 2014 by Thomas Fox

According to This Day in History, 139 years ago today, Billy the Kid was arrested for the first time, for theft. Billy the Kid was believed to have been born in New York City and was later taken out west by his mother. He was arrested on September 23... Read More

Transparency International’s Progress Report
Posted on 10 Oct 2013 by Mike Koehler

This article was reprinted with permission from FCPA Professor Transparency International (TI) does good work in raising awareness of bribery and its effects and seeking to reduce bribery and corruption around the world. Yet, every time I read TI’s... Read More

  • Blog Post: FCPA Enforcement: Why the Increase between the First 25 Years and the Last 5?

    On Thursday, March 10, the World Compliance Tour came to Houston. It featured presentations by Michael Volkov, of the law firm of Mayer Brown; Ryan Morgan, of World Compliance; and Richard Cassin, author of the FCPA Blog . The session was very informative on a wide range of topics related to the Foreign...
  • Blog Post: Fast and Furious: Corruption in Brazil and Upcoming World Cup and Olympics

    I recently saw the latest installment of the Fast and Furious franchise, entitled "Fast Five". In this installment, Vin Diesel as Dominic Toretto and Paul Walker as Brian O'Conner led a team which steals over $100 million from a Brazilian crime boss. One of the storylines of the movie...
  • Blog Post: The Biomet SEC Complaint: Lessons for Internal Audit

    On March 26, 2012, both the Securities and Exchange Commission (SEC) and the Department of Justice (DOJ) announced the resolution of enforcement actions against Biomet Inc. a US entity, which manufactures and sells global medical devices around the world. It is headquartered in Fort Wayne, Indiana...
  • Blog Post: Isn’t It Ironic, Don’t You Think?

    This article was reprinted with permission from FCPA Professor [Proper citation to Alanis Morissette is in order, this song makes for good background music as well for this post] This post has been in the works for some time, but with the recent political conventions ending and the election...
  • Blog Post: Show Me the Money – Employee Compensation to Prevent Bribery and Corruption

    The GlaxoSmithKline PLC (GSK) matter continues to resonate across the compliance world. Ongoing news releases by the company and announcements from named and un-named sources on the underlying facts continue to generate press worldwide. But there are also several important lessons to be learned from...
  • Blog Post: Scalping Tickets and the Use of Fake Invoices in China

    I long ago learned that there is no such thing as a ‘sold out event’; as the scalping of and for tickets to sports events is a long and time honored tradition. However with the advent of such websites as StubHub.com, it certainly has never been easier to purchase tickets to any concern or...
  • Blog Post: Transparency International’s Progress Report

    This article was reprinted with permission from FCPA Professor Transparency International (TI) does good work in raising awareness of bribery and its effects and seeking to reduce bribery and corruption around the world. Yet, every time I read TI’s annual progress report on OECD Anti-Bribery...
  • Blog Post: Secretary of State Kerry Gets It Right

    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 of Commerce participants in Poland, Secretary of...
  • Blog Post: The Sussex Vampyre and the ADM FCPA Settlement

    Today I want to use the story of The Sussex Vampyre as the starting point for an inquiry into the recent Archer-Daniels-Midland Corp (ADM) Foreign Corrupt Practices Act (FCPA) enforcement action. In the story, Holmes receives a letter from Robert Ferguson, who has become convinced that his second wife...
  • Blog Post: GSK Convicted – We Are Really, Really Sorry We Paid Bribes (and Got Caught)

    “GSK plc sincerely apologies to the Chinese patients, doctors and hospitals, and the Chinese Government and the Chinese people.” With those words, the British pharmaceutical giant GlaxoSmithKline (GSK) PLC was convicted in a secret trial in a court in the Hunan province of China for bribery...
  • Blog Post: Billy the Kid Begins and the GSK China Verdict

    According to This Day in History, 139 years ago today, Billy the Kid was arrested for the first time, for theft. Billy the Kid was believed to have been born in New York City and was later taken out west by his mother. He was arrested on September 23, 1875 when he was found in possession of clothing...
  • Blog Post: Corruption Is Bad, But What Is It?

    This article was reprinted with permission from FCPA Professor Last week, International Anti-Corruption Day was recognized. This short White House press release used the word “corruption” 13 times. DOJ Assistant Attorney General Leslie Caldwell co-authored this short Huffington Post...