How to message with due diligence
Posted on 05-06-2019 by Lisa Thompson

In March, the U.S. Department of Justice (DOJ) issued revised guidance for the Foreign Corrupt Practices Act’s (FCPA) Corporate Enforcement Policy (CEP) concerning the adoption of rules and regulations around the use of ephemeral messaging platforms, such as Snapchat, WeChat or Telegram for business... Read More

Frontline compliance requires expert juggling
Posted on 04-18-2019 by Lisa Thompson

There’s no room for clowning about when it comes to risk management and maintaining the integrity of international business. According to records of ancient Chinese history, the armies of the Chu and Song states were facing each other in readiness for battle in 630 BC when a Chu warrior, Xiong... Read More

1.1 Billion Reasons Companies Need a Robust FCPA Compliance Process
Posted on 04-17-2019 by Lisa Thompson

There were only three FCPA enforcement actions in the first quarter of 2019, but the small number obscures a bigger threat to corporate bottom lines—fines totalling $1.1 billion. This figure eclipses the total settlements in Q1 2018—also for three corporate enforcement actions—of a... Read More

Operation Varsity Blues Makes the Case for ISO 37001 Adoption
Posted on 04-12-2019 by Lisa Thompson

Is anyone really surprised by the college admissions bribery scandal? Sure, it’s nice to think that academia is a bastion for the best and the brightest. But there’s a longstanding tradition where the family name—and perhaps an endowment—greases the wheels for less academically... Read More

Corporate Social Responsibility and Compliance to Join Top Table at Davos
Posted on 01-22-2019 by Lisa Thompson

The World Economic Forum (WEF) brings together leaders of government and business in the Alpine town of Davos in Switzerland this week. They are discussing the latest trends in business and society. The participant list is revealing—this year, some of the world’s biggest companies have sent... Read More

Weighing risk and opportunity in Latin America
Posted on 01-16-2019 by Lisa Thompson

Despite recent Foreign Corrupt Practices Act (FCPA) enforcement actions, there are signs of more positive engagement with governance and compliance in Latin America. Emerging markets offer attractive opportunities for investors, but businesses aiming to capitalize will need to prioritize robust due diligence... Read More

Bribery in pharma: What you need to know
Posted on 01-07-2019 by Lisa Thompson

The pharmaceutical sector is one of the most-at risk industries for bribery and corruption. In a new White Paper, we look at some of the recent bribery enforcement actions against pharma firms and strengthened anti-bribery legislation. And we suggest ten steps for enhanced risk mitigation. Rising... Read More

3 Business Resolutions that Reduce Risk Exposure
Posted on 12-21-2018 by Lisa Thompson

January may be hot or cold, rainy or snowy—it just depends on where you live. But whether you sport a windbreaker or a parka when you head back to work after the holiday season, January is the same everywhere when it comes to making resolutions. It marks a new year and a clean slate—which... Read More

The Foreign Corrupt Practices Act—2018 review
Posted on 12-20-2018 by Lisa Thompson

2018 has been a record year of penalties issued for breaches of the Foreign Corrupt Practices Act (FCPA). Settlements totaling more than $2.96 billion were agreed by corporations found to be in breach of the Act. The year saw further indications of the FCPA’s global reach, witnessed the first judgments... Read More

Enter the ninja: A disciplined approach to defeat regulatory risk
Posted on 12-05-2018 by Lisa Thompson

Forget about the turtles. Today is International Ninja Day, but what we’re on about has more to do with regulatory risk than teenagers or (as far as we know) mutants. Why does International Ninja Day make us think ‘compliance program’? International Ninja Day was the brainchild of... Read More

Is the Defense Industry armed to beat corruption risk?
Posted on 11-29-2018 by Lisa Thompson

Corruption is a significant problem—no matter what sector it originates in. But a recent report from corruption watchdog Transparency International takes aim at one industry in particular: Defense. The report notes, “While it may be true that much has changed over the last two or three decades... Read More

A new No. 1: Petrobras agrees to biggest FCPA settlement
Posted on 10-05-2018 by Lisa Thompson

Petrobras has reached a $1.78 billion settlement with the DOJ and SEC over bribes to politicians and political parties in Brazil. This is the first time an enforcement action over FCPA violations has exceeded a billion dollars. The amount is bigger than the nearest two settlements combined, and the case... Read More

FCPA Corporate Enforcement Policy extended to M&A
Posted on 09-17-2018 by Lisa Thompson

The U.S. Corporate Enforcement Policy, which incentivises companies to self-disclose bribery and corruption when they come across it, now applies to U.S. companies which are merging with or acquiring foreign companies. That’s according to a recent speech by a senior official at the Department of... Read More

Compliance risk in the UK: what companies need to know
Posted on 08-29-2018 by Lisa Thompson

The global compliance landscape is becoming ever more complex, and some of the most significant recent developments in ABC and AML legislation have happened in the UK. All companies who operate in the UK need to be aware of these laws, as well as growing consumer expectations of ethical behavior, if... Read More

Why the Energy Sector Needs Better Due Diligence & Risk Monitoring
Posted on 08-23-2018 by Lisa Thompson

No industry is impervious to bribery and corruption risk, but companies linked to energy industries, in particular, face elevated risks in order to reap the equally-high rewards. It’s a topic we’ve touched on in blog posts on Unaoil and Petrobras . But anti-bribery and corruption regulations... Read More

Danske Bank and Siemens invite ABC compliance in the boardroom
Posted on 08-16-2018 by Lisa Thompson

Danske Bank and Siemens have appointed chief compliance officers to their boards of directors this summer. We explore why compliance has become accepted as a critical function in any company. At the next board meeting of Denmark’s biggest bank, a chief compliance officer will be at... Read More

Why Pharma & Biomed Companies’ Risk Analysis Processes are Due for a Check-Up
Posted on 07-18-2018 by Lisa Thompson

Just three years ago, Teva Pharmaceuticals, a drug-maker in Israel, disclosed to both the U.S. Securities & Exchange Commission and the U.S. Department of Justice that an on-going internal probe had revealed possible violations of the Foreign Corrupt Practices Act (FCPA) and/or local laws. Ultimately... Read More

FCPA Hangover: Whiskey Maker's $8M Settlement Puts Food & Drink Industry on Notice
Posted on 07-13-2018 by Lisa Thompson

The makers of Jim Beam whisky have paid $8 million to settle allegations of bribing government officials to enter the Indian market. The settlement is a timely reminder of the continued threat of FCPA enforcement action , and the particular risks posed by third parties in the food and drink industry... Read More

Regulatory Risk in the U.S.: What Companies Need to Know
Posted on 04-27-2018 by Lisa Thompson

Since its introduction of the Foreign Corrupt Practices Act (FCPA) in 1977, the United States has led the world in efforts to counter bribery and corruption in corporate business that traverses national borders. Now it has gone a full step further with permanent adoption and expansion of its Corporate... Read More

Six lessons from 2017 FCPA enforcement actions
Posted on 01-11-2018 by Ulyana Androsova

Last year, 11 companies paid just over $1.92 billion to resolve US Foreign Corrupt Practices Act (FCPA) enforcement actions. We take a closer look at the biggest fines and draw out six lessons on how companies should respond to bribery and corruption risks. Fines are getting bigger The total number... Read More

Transparency International’s 2016 Corruption Perceptions Index released
Posted on 02-01-2017 by Ulyana Androsova

Transparency International has released its 2016 Corruption Perceptions Index (CPI). The CPI ranks 176 countries and territories on how corrupt their public sector is perceived to be. The index aggregates a number of different sources, including the views of business people and country experts. Global... Read More

2016 FCPA Enforcement Actions Demonstrate Global Reach
Posted on 01-19-2017 by Ulyana Androsova

Israel, Brazil, United States, Netherlands—companies headquartered in each of these countries settled U.S. Foreign Corrupt Practices Act (FCPA) enforcement actions in 2016 . They weren’t alone; 23 other companies in countries around the world faced similar actions, driving the amounts paid... Read More

Effective due diligence the best medicine for the pharmaceutical industry
Posted on 08-12-2015 by Ulyana Androsova

The pharmaceutical industry has been impacted by globalization more than most. Where there was traditionally a significant difference between the levels of healthcare and well-being between the developed and developing worlds, there has been rapid and complex change. With an increased demand for cures... Read More

Do you think your pre-M&A due diligence is digging deep enough?
Posted on 08-11-2015 by Ulyana Androsova

It’s a given that before any merger or acquisition, your company conducts due diligence. The question is, are you drilling down to the right information? Financial due diligence is important, of course, but it only scratches the surface. These days, conducting business—including M&A activity... Read More

Where will the FIFA FCPA Investigations End?
Posted on 07-29-2015 by Ulyana Androsova

When the final match of the FIFA Women’s World Cup Canada™ concluded earlier this month, the fans of the U.S. women’s soccer team celebrated, and for a moment, FIFA was in the spotlight for good reason. The Women’s World Cup generated a lot of interest—so much, in fact,... Read More