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...
In an article entitled, " Risks and Rewards of an
Independent Investigation " in the October 2010 issue of the ACCDocket , authors James McGrath and David Hildebrandt discuss the use of specialized
outside counsel to lead an independent internal...
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...
In November, 2009 the Organization for Economic and Co-operation and Development (OECD)
announced a new recommendation at the OECD's celebration of "International
Anti-Corruption Day" and the Tenth Anniversary of the " Entry into...
This article concludes our series on what we believe to be
the Top 3 Foreign Corrupt Practices Act (FCPA) cases in the first half of 2010.
We have reviewed the facts surrounding each matter to come up with lessons that
the FCPA compliance professional...
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...
Inspired by our colleague, the FCPA Professor , this post will
pose several questions regarding the Foreign Corrupt Practices Act (FCPA) in
connection with one of the most Byzantine litigation matters of current renown,
that being Chevron's legal...
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...
At most Foreign Corrupt
Practices Act (FCPA) compliance and ethics training sessions there is usually
one or more archetypal story about "someone I know" who was solicited to pay a
bribe or "I heard about someone" from whom a bribe...
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...
enforcement of the Foreign Corrupt Practices Act (FCPA) be suspended for those
US companies now working in Haiti? This topic has been in discussion for a few
weeks. It began with a statement by Wall Street Journal editorial board member
We were recently introduced to Fraud Examiner Expert Tracy Coenen , in her
book " Expert Fraud Investigation: A Step-By-Step Guide " she details the
steps a company should go through in performing a fraud investigation. Coenen
The baseball season is upon us and the Houston Astros
have opened with their worst start since 1983. At 3-9, things may be looking a
bit bleak for the hometown heroes. However several sportswriters have pointed
out that the 1983 team ended up with...
We recently wrote about gifts and entertainment under the Foreign Corrupt Practices Act (FCPA). To view the prior article, click here . This week the Securities and Exchange Commission (SEC) announced an enforcement action involving Veraz Networks. The...
At its April 7,
2010 meeting the United States Sentencing Commission approved amendments to its
Sentencing Guidelines . The next
day on April 8, 2010, the UK Bribery
Bill received Royal Assent. These two events follow the December 9, 2009