This article was reprinted with permission from FCPA Professor Intelligize, Inc., a corporate compliance resource provider, recently released a report titled " Managing Risk Better in 2013 ." The report tracks public company disclosures...
What do national pastimes teach us about ethics and compliance? I would argue plenty. While, for the most part, I have reserved myself from writing about the Houston Astros fraud upon their fans this season in claiming that (1) they are fielding a...
This article was reprinted with permission from FCPA Professor SEC tweaks its neither admit nor deny settlement policy, Tyco settlement approved, scrutiny alert, and for the reading stack. It's all here in the Friday roundup. SEC Tweaks Neither...
Earlier this week, Jim McGrath, writing in his Internal Investigations Blog , posted a blog entitled " Human Trafficking Concerns for 7-Eleven in Wake of Payroll Scam ". In this post McGrath reviewed the seizure of "fourteen 7-Eleven...
The banking world is littered with institutions that have paid astronomical fines for their failures around anti-money laundering (AML) legislation. Much has been written and said about these events. However one of the areas that has received perhaps...
Calling FCPA and anti-corruption enforcement a "core priority of the Department of Justice," Mythili Raman, Acting Assistant Attorney General, Criminal Division, recounted the Department's successes across the nation and its coordination...
One of the things that has long puzzled me is what led to the significant rise in the enforcement of the Foreign Corrupt Practices Act (FCPA) beginning in the 2003-2004 time frame? One of the more consistent theories that I have heard proffered, by...
This article was reprinted with permission from FCPA Professor Survey says, an editorial, I'll second that, and spot-on. It's all here in the Friday roundup. Survey Says The recently issued Kroll / Compliance Week Anti-Bribery and...
"We are not the 'serious champagne office,' " said David Green , chief of the UK's Serious Fraud Office (SFO). But Green says he is working to focus his agency on bigger cases of bribery and corruption. Green's commitment ...
For anyone who grew up in the 1960s, I am sure that you remember the touchstone slogan for Tareyton cigarettes, " I'd rather fight than switch ". The television ad always showed someone with a black eye and a Tareyton cigarette in his...
This article was reprinted with permission from FCPA Professor [This post is part of a periodic series regarding "old" FCPA enforcement actions] In 1989 the DOJ charged (see here ) Goodyear International Corp., a subsidiary of Goodyear...
Not many people realize that the US has elected one president who served as a prisoner of war. That man was Andrew Jackson, who was captured by the British during the Revolutionary War. Now, can you name the American President who killed another man...
With fewer recent cases there has been a lot of speculation suggesting that perhaps enforcement officials were easing-up on the FCPA. That supposition just ended with a new addition to the FCPA Top 10, maintained by the excellent FCPA blog. French...
Can you synthesize and reconcile the world's leading laws, regulations and commentaries on the best practices an anti-bribery and anti-corruption compliance program? I recently saw one such approach by Paul McNulty and Stephen Martin of the law firm...
This article was reprinted with permission from FCPA Professor [This post is part of a periodic series regarding "old" FCPA enforcement actions] In 1986 the SEC brought this civil injunctive action against Ashland Oil, Inc. (a Kentucky...
One does not have to look very far in the business world to come across the phrase "Know Your Customer." A company certainly needs to know if an entity that it may sell products or provide services to will pay for those items. Running a Dun...
This article was reprinted with permission from FCPA Professor $1.16 million in FCPA professional fees and expenses per working day , show me the numbers, quotable, and for the reading stack. It's all here in the Friday roundup. Wal-Mart's...
Sometimes a story will help you understand just what you did not understand. Did you know that the Federal Bureau of Investigation (FBI) launched a formal investigation in 1964 into the supposedly pornographic lyrics of the song " Louie, Louie...
This article was reprinted with permission from FCPA Professor It is a common FCPA Inc. marketing device. Pluck any FCPA-related item from the news and use that news as the hook to write about FCPA compliance services. Profile any recent instance...
Billie Sol Estes died yesterday and when it comes to scam artists from the great state of Texas, before there was Allen Stanford and his magical Certificates of Deposits located in his private bank in Antigua, there was Billie Sol Estes. Before Sir...
Has the Perfect FCPA Storm Finally Arrived for U.S. Financial Markets? This case may be the catalyst that jump-starts a government FCPA sweep of Wall Street that has been predicted since 2011, but not realized. On May 7, 2013, the U.S. Attorney's...
I often marvel at some of the stories which come up in the context of Foreign Corrupt Practices Act (FCPA) investigations and enforcement. If you made up some of the things which are reported, I fear that people might find you simply crazy. One of...
DOJ and SEC enforcement officials have made it clear in recent years that anticorruption and FCPA enforcement is a key priority. More cases have been brought in the last several years than in the history of the Act. Huge sums are being paid by increasing...
This article was reprinted with permission from FCPA Professor During the panel session on DOJ non-prosecution and deferred prosecution agreements last week at the Corporate Crime Reporter sponsored conference in Washington, D.C., I shared my...
This article was reprinted with permission from FCPA Professor Additional individual defendant added to Alstom-related enforcement action, a mere $110,000 per working day, a focus on international philanthropy, scrutiny alerts, and for the reading...