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    The Maxwell Technologies Fallout: the Alain Riedo Indictment for FCPA Violations

    Today is the 82 nd anniversary of the reporting to Alcatraz Prison of one of its most memorable residents; Al Capone. Capone was sent to prison for income tax evasion; in other words, it was a books and records violation, albeit a very, very large one...

    SEC Enforcement Official Acknowledges the Underlying Logic Supporting a Compliance Defense

    This article was reprinted with permission from FCPA Professor There is an underlying logic to a Foreign Corrupt Practices Act compliance defense. In “ Revisiting a Foreign Corrupt Practices Act Compliance Defense ,” I argued, among...

    Dan Snyder, the CCO and Doing Business Ethically

    We continue the football theme as an entrée into compliance by looking at Washington Redskins owner Daniel Snyder. I am a life-long Dallas Cowboys fan so having someone like Snyder as the owner of your main rival at the professional level is almost...

    Friday FCPA Roundup for Week Ending Oct. 11

    This article was reprinted with permission from FCPA Professor Scrutiny alert, potential fallout, act like a cop be treated like a cop, and for the reading stack. It’s all here in the Friday Roundup. Scrutiny Alert Leighton Holdings Limited...

    Will World Cup 2022 Become World Cup 2023?

    SPOILER ALERT – This article reveals that the temperature becomes quite hot in Qatar in the summer months. That paragon of compliance and ethics, the world’s richest and most influential single-sport ruling body Fédération...

    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...

    Due Diligence: Past, Present and Future

    Released 40 years ago this month, the Al Stewart album Past Present and Future was a departure from his earlier folk based work. In this album, Stewart focused on historical themes. I was particularly drawn to two long songs, “Roads To Moscow”...

    And The Apple Goes To … (October 2013)

    This article was reprinted with permission from FCPA Professor Fall. The colors are changing and the apples are crisp. This month’s FCPA Professor Apple Award goes to … U.S. District Court Judge Richard Sullivan (S.D.N.Y.). According...

    Friday FCPA Roundup for Week Ending Oct. 4

    This article was reprinted with permission from FCPA Professor Scrutiny alerts, coming clean, coming off a monitor, and for the reading stack. It’s all here in the Friday roundup. Scrutiny Alerts Hyperdynamics This previous post, regarding...

    Financial Controls in a Best Practices Compliance Program

    Financial controls are rarely given top billing in an anti-corruption compliance program under the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act. However, it turns out that financial controls are essential to the long term success of not only...

    FCPA: What You Need To Know From Q3

    This article was reprinted with permission from FCPA Professor This post provides a summary of Foreign Corrupt Practices Act activity and related developments from the third quarter of 2013. See here for a similar post from Q1, here for Q2. DOJ...

    The Cost of Stupid is Less Than the Cost of Bribery and Corruption

    After the butt-slide play, you might think that the sad sack Houston Astros could not sink even lower but I guess setting the Major League Baseball (MLB) record for the worst record for three straight years is not enough. Yesterday, as reported by Sam...

    Getting Your Employees to Internally Market Your Compliance Program

    It has often struck me that one of the things the compliance function must do is to internally market its role in a company. By this I do not mean the internal competition for funding that occurs annually, although that is certainly something which the...

    Friday FCPA Roundup for Week Ending Sept. 20

    This article was reprinted with permission from FCPA Professor A roundup of comments made yesterday by Charles Duross (DOJ FCPA Unit Chief) and Kara Brockmeyer (SEC FCPA Unit Chief) at the ABA’s National Institute on the Foreign Corrupt Practices...

    Survey Says

    This article was reprinted with permission from FCPA Professor Call them green, inexperienced, and naive as to how things really work. I call them good Foreign Corrupt Practices Act survey respondents because they are immersed in learning: (i) about...

    Should Motivations Matter?

    This article was reprinted with permission from FCPA Professor GlaxoSmithKline’s (GSK) scrutiny in China – by the Chinese government – dominated the headlines in July (see here for a prior post). Shortly thereafter, many began...

    The Red Baron and Leading in Compliance

    For anyone who grew up in the 60s or 70s; the comic strip adventures of Snoopy vs. the Red Baron were legendary. ‘ Curse You Red Baron’ was a routine line from Snoopy as he was foiled time and time again by the Red Baron. Anyone who has seen...

    Friday FCPA Roundup for Week Ending Sept. 13

    This article was reprinted with permission from FCPA Professor It’s an FCPA world Friday roundup. According to my tally, in the last approximate 30 days, 11 companies have disclosed new instances of FCPA scrutiny and/or otherwise been the...

    The Convergence of Bear Bryant and Johnny Football – Lessons In Compliance

    Sedona Arizona is known for its four vortexes, some of those alleged places where the universe has holes in it or overlaps (I can’t remember which). I have been to Sedona but I have never experienced such convergence (or the voids for that matter...

    Don’t Believe the Hype on SEC Statute of Limitations

    This article was reprinted with permission from FCPA Professor The statute of limitations is a fundamental legal principle setting a fixed period of time to file a lawsuit after a claim arises. Last term in Gabelli v. SEC [ an enhanced version of this...

    How to Build a Culture of Ethics and Compliance: the Greatest Article Ever – Part III

    Today I conclude my exploration of the article in the summer 2013 issue of the MIT Sloan Management Review, entitled “ Designing Trustworthy Organizations ”, by the quartet of authors: Robert F. Hurley, Nicole Gillespie, Donald L. Ferrin and...

    Friday FCPA Roundup for Week Ending Sept. 6

    This article was reprinted with permission from FCPA Professor Interesting, hardly a smoking gun, law enforcement ought not be a competition, quotable, and for the reading stack. It’s all here in the Friday roundup. Interesting An interesting...

    How to Build a Culture of Ethics and Compliance: the Greatest Article Ever – Part II

    In this post I continue my exploration of the article in the summer 2013 issue of the MIT Sloan Management Review, entitled “ Designing Trustworthy Organizations ”, by the quartet of authors: Robert F. Hurley, Nicole Gillespie, Donald L. Ferrin...

    Friday FCPA Roundup for Week Ending August 30

    This article was reprinted with permission from FCPA Professor Scrutiny updates and alerts, a double standard, upcoming events, and for the reading stack. It’s all here in the Friday roundup. Scrutiny Updates and Alerts JPMorgan In this...

    Send in the Clowns – the NCAA and its Investigation of Johnny Football

    How can you determine if an organization charged with compliance is corrupt or simply incompetent? It is hard today to answer that question when it comes to the National Collegiate Athletic Association (NCAA) and its enforcement division. For those of...