At the " Examining Enforcement of the
Foreign Corrupt Practices Act " hearings on November 30, 2010, before
the US Senate Judiciary Committee ,
Subcommittee on Crime and Drugs, Michael Volkov presented an interesting idea
which he believes...
The U.S. is investigating Allianz SE, for possible
bribery by a German printing press company in which it holds a majority stake
according to a story
by Joe Palazzolo in WSJ.com's Corruption Currents .
The Foreign Corrupt Practices Act bars...
We recently came across an article entitled, " Coordinating
Investigations Between US Companies and their Subsidiaries or Suppliers
Overseas ", by two Jones Day
Edwards and Gillian
Garrett . While not strictly focused on...
We believe that Risk Assessment is a tool and is one with
which a company should begin to craft its Foreign Corrupt Practices (FCPA) or
UK Bribery Act compliance program. The simple reason is straightforward; one
cannot define, plan for, or design...
As was initially reported by the FCPA
Professor , lawyers for four of the individual defendants who are former
executives of the Orange County, California-based valve company, Control
Components Inc. have filed a Motion to Dismiss the DOJ's case...
The task of where to begin a full compliance and ethics
program can often times appear quite daunting. Most US companies fully
understand the need to comply with the Foreign Corrupt Practices Act (FCPA).
However most companies are not created out of...
All compliance programs are designed to prevent, detect
and deter ethical violations. In the United States, they are also designed to
bring companies into compliance with the Foreign Corrupt Practices Act (FCPA).
However, as important as these programs...
In an article in the January/February issue of the ACC Docket , entitled " Guilt
by Association: Transnational Joint Ventures and the FCPA " [membership required]; Dennis Haist , General
Counsel of The Steele Foundation
Here's a tip for potential Foreign
Corrupt Practices Act whistleblowers: travel expenses clearly fall within
A FCPA whistleblower is often
an employee or insider who often times assumes incorrectly that a bribe only
The Department of Justice and the SEC settled FCPA cases with Alcantel-Lucent S.A., a company formed in a November 30, 2006 merger involving Paris, France based Alcantel, S.A. and U.S. based Lucent Technologies, Inc. U.S. v. Alcatel-Lucent S.A. , (S.D...
One of the interesting facts of life that I have learned
being married to an English woman is that what I thought of as 'Football' is
really 'American Football'. The true game of 'Football' is played by the rest
of the world...
In our most recent
post , we wrote about an article by Dennis Haist , General
Counsel of the Steele Foundation ,
which recently appeared in the ACC
Docket . The article was entitled, " Guilt by Association:
Transnational Joint Ventures and...
The FCPA year in 2010 has been quite interesting. As the year is ending I wanted to put forth some of the more significant enforcement actions for the FCPA practitioner to provide lessons learned and perhaps some educational opportunities for all our...
In an article in the January/February issue of the ACC Docket entitled " Five
Fundamentals for Taking Management Compliance Seriously " , author Daniel
Lucien Buhr discusses a model for a compliance system which he describes as
In the most recent issue of the Harvard
Business Review , writers Linda Hill and Kent Lineback posed the question, " Are You a
Good Boss - Or a Great One ?" In this article they explore what they
believe to be some of the imperatives of going...