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FCPA and Bribery Act Best Practices- Written Compliance Policies and Procedures

One of the areas which is universally listed as a component of a best practices compliance policy under the Foreign Corrupt Practices Act (FCPA), UK Bribery Act and OECD Good Practices is that of a written compliance code. However this is not an area that most compliance practitioners spend much...

The FCPA in Emerging Markets: Evaluating Risks of Bribery and Corruption

I am attending the 2011 Global Ethics Summit this week in New York City. It is presented by Ethisphere and Thomson Reuters . This post will be first of several based upon the comments of the panelists. In today's posting we will discuss some of the issues faced in emerging markets, regarding anti...

FCPA Lessons Learned-Failures in Internal Controls

We often write and speak on some of the lesson learned from enforcement actions brought by the Department of Justice (DOJ) under the Foreign Corrupt Practices Act (FCPA). We believe that companies can not only learn from the mistakes of others in implementing or enhancing their compliance program...

Johnson & Johnson Deferred Prosecution Agreement-Part I: Self-Disclosure Reduces Fine

On April 8, 2011, the Wall Street Journal (WSJ) reported that Johnson & Johnson settled certain charges related to violations of the Foreign Corrupt Practices Act (FCPA) with the Department of Justice (DOJ) and Securities and Exchange Commission (SEC). The settlement was in the mechanism of a...

Recent DPAs Provide Guidance on FCPA Compliance Best Practices

The House Judiciary Committee will hold hearings Tuesday on the Foreign Corrupt Practices Act. At this point the Witness List as set forth on the Committee's website is as follows: Hon. Michael Mukasey Former Attorney General Partner Debevoise & Plimpton LLP...