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Foreign Business Partner under the FCPA: The Problem and Managing It

This article is the first in a series of articles detailing the risk assessment, evaluation and management of a foreign business partner under the Foreign Corrupt Practices Act (FCPA). This article sets out the parameters of the problem and suggests a format for risk assessment, suggesting an approach...

How Do You Evaluate a Risk Assessment?

What is the amount of risk that your company is willing to accept? Before you even get to this question how does your company assess risk and subsequently evaluate that risk? In the July issue of the Compliance Week magazine, these questions were explored in an article entitled " Improving Risk...

Risk Management – More than Just Risk Assessment

In an article in the December edition of the ACC Docket, entitled " Disciplined and Practical Risk Management ", Jim Jackson, General Counsel of Medair, discussed risk management in the non-profit arena, focusing on his experiences on this issue during his tenure at Medair. Medair is an...

Risk Assessments under the UK Bribery Act

In the February 10, 2012 edition of the Houston Business Journal, in an article entitled " In order to solve a problem, it must first be identified ", author Harvey Mackay wrote "People don't usually buy products and services. They buy solutions to problems." He notes that...

OCEG Illustrated Series: Managing Corruption Risks

How do you move off dead center? That was a question posed by my colleague Mary Jones in a recent guest blog post. She gave several concrete steps in answer to her own question. This question was further explored in the January issue of the Compliance Week magazine which began a six-part " Anti...

Michael Bell on Vendor Risk Touchpoints

by Michael Bell It is often challenging to pinpoint specific sources of risk when law firms engage or supervise a third-party legal vendor. Focusing on the the sources of risk, or touchpoints, that create a disproportional level of exposure is an essential first step when conducting a comprehensive...

The Looming "Fiscal Cliff" and Business Risk

Next Tuesday, the country will elect its President for the next four years. Exactly one week later, Congress will return to take up a critical piece of deferred business that could dramatically affect the country for the next four years and even beyond, regardless of who wins the Presidential election...

Scam Artists from Texas and Compliance Risk Management

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 Allen came along, Billie Sol had a 50 year run as...

Risk Assessments-the Cornerstone of Your Compliance Program, Part I

Yesterday, I blogged about the Desktop Risk Assessment . I received so many comments and views about the post, I was inspired to put together a longer post on the topic of risk assessments more generally. Of course I got carried away so today, I will begin a three-part series on risk assessments. In...

Risk Assessments-the Cornerstone of Your Compliance Program, Part II

Ed. Note-Today, I continue my three-part posts on risk assessments. Today I take a look at some different ideas on how you might go about assessing your risks. One of the questions that I hear most often is how does one actually perform a risk assessment? Mike Volkov has suggested a couple of different...

Risk Assessments-the Cornerstone of Your Compliance Program, Part III

Today, I conclude a three-part series on risk assessments in your Foreign Corrupt Practices Act (FCPA) or UK Bribery Act anti-corruption compliance program. I previously reviewed some of the risks that you need to assess and how you might go about assessing them. Today I want to consider some thoughts...

Economic Downturn Week, Part III – The Desktop Risk Assessment

I continue my exploration of actions you can take to improve your compliance program during an economic downturn with a review of what my colleague Jan Farley, the Chief Compliance Officer (CCO) at Dresser-Rand, called the ‘ Desktop Risk Assessment ’. Both the Department of Justice (DOJ)...

Layla and Other Love Songs and Risk Assessments

On this date in October 1971, Duane Allman died. He was the co-founder, along with his brother Greg, of the Allman Brothers Band. For my money he was one of the greatest guitarists of all time. At the time of his death, the Allman Brothers had released their debut album, simply entitled The Allman Brothers...