In his Editor's View column, in the August issue of Compliance Week , entitled, " Compliance,
Collaboration and HR ", Matt Kelly wrote about the interaction of
Compliance Departments and Human Resources (HR). He noted that while Compliance...
In an article published in the July 29, 2011 issue of the
Houston Business Journal
entitled " Eight
Steps to a More Effective Anticorruption Compliance Function " Chris
Lozier , Principal at UHY Advisors in Houston and Manager of the FCPA...
In Part I of Reading
a Crystal Ball? Guidance on Instrumentality under the FCPA , we listed
the factors which the three federal district courts have set forth for the
determination of whether an entity is an instrumentality under the Foreign
I had intended to post Part II of my series the recent
court rulings on instrumentalities. However, sometimes events overtake you. In
the world of the Foreign Corrupt Practices Act (FCPA), some of the fact
scenarios are so preposterous that if they...
One the criticisms of the Foreign Corrupt Practices Act
(FCPA) is that it provides little guidance as to what constitutes an
instrumentality under the Act and attendant question of who is a foreign
governmental official. One of the five points raised...
In an article published in the June issue of ACC Docket,
entitled " Playing the Cards You're Dealt ", James Nortz raised the
interesting issue of the lack of company leadership to "create an ethical
vision, the moral courage to pursue...
In a recent post entitled " Will
No One Rid Me of this Meddlesome Priest? " I highlighted 'Tone at the
Top' by discussing the words of Henry II leading to the subsequent murder of
Thomas Becket. One of the things I learned on my recent...