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Issues to Consider From the Bristol-Myers Enforcement Action
This recent post highlighted the SEC’s FCPA enforcement action against Bristol-Myers.This post continues the analysis by highlighting various issues to consider from the enforcement action.False and...
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Friday FCPA Roundup for Week Ending October 9
This article was reprinted with permission from FCPA ProfessorAlleged bribery at the U.N., former Siemens exec pleads guilty to long-standing charges, scrutiny alerts and updates, quotable, and for the...
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Compliance at the Tipping Point, Part I – The Yates Memo
This is the day that the US government traditionally celebrates Columbus’ discovery of the Americas, in the form of Columbus Day. My grandfather emigrated from Italy so he always took Columbus Day as...
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A Government Required Transfer of Shareholder Wealth to FCPA Inc.?
This article was reprinted with permission from FCPA ProfessorThis is the third time FCPA Professor has highlighted this specific topic.The prior two posts (here and here) were in connection with FCPA...
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Compliance at the Tipping Point, Part II – New DOJ Compliance Counsel
The second tipping point for compliance which has occurred over the last 30 days or so is the information which has leaked out that the Department of Justice (DOJ) is in the process of hiring an...
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Developments From Across the Pond
This article was reprinted with permission from FCPA ProfessorA few developments from the United Kingdom worth highlighting.SFO SpeechIn this recent speech, David Green (Director of the SFO)...
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Compliance at the Tipping Point, Part IV – The Schrems Decision
I continue my exploration of why I believe that compliance is at the Tipping Point, with today’s entry of data point four, which is last week’s decision by the European Court of Justice (ECJ) in the...
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Friday FCPA Roundup for Week Ending October 16
This article was reprinted with permission from FCPA ProfessorRama sentenced but what is the back story, scrutiny alert, and for the reading stack. It’s all here in the Friday roundup.Rama Sentenced,...
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Compliance at the Tipping Point, Part V – Protection Afforded From a...
Today, I wrap up my series on why I think compliance is at the Tipping Point. However as it is a Friday in October, I continue my tribute to the Man in the Shadows, producer Val Lewton, whose films for...
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Compliance Connected – Line of Sight, Part I
Sometimes the simplest visual can provide the greatest insight about transformation. I had that particular insight when I recently had the chance to catch up with Scott Lane, Chief Executive of the Red...
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Wall Street Journal Pulls a Nana Nana Boo Boo on the New York Times Walmart...
This article was reprinted with permission from FCPA ProfessorOn Monday, the Wall Street Journal published this page one article titled “Wal-Mart Bribery Probe Finds Few Signs of Major Misconduct in...
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The World Bank: Lending & Developing Without Corruption
The World Bank recently assessed a project relating to the funding of power stations in South Africa. The World Bank’s initial assessment appears to have cascaded from an SEC enforcement action with...
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Compliance Connected – Line of Sight, Part II
Today I continue my exploration of the line of sight theory under which a Chief Compliance Officer (CCO) or compliance practitioner would have visibility across the lifecycle of a sales transaction so...
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A Holistic Approach to Third-Party Risk & Due Diligence
The following interview is with Leas Bachatene, CEO at ethiXbase.Hi Leas, thank you for participating in today’s Q and A. I have really enjoyed working with the ethiXbase team, including on our recent...
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Booking a Meeting? In Venezuela It May Cost You a Rolex
First it was Petrobras but it certainly did not take long for the second shoe to drop for the other corrupt national energy company in Latin America, the Venezuelan national oil company Petróleos de...
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Reading Assignment: The Latest Judicial Opinion Regarding the DOJ’s Use of DPAs
This article was reprinted with permission from FCPA ProfessorIf you have an interest in the DOJ’s frequent use of deferred prosecution agreements (DPAs), then this recent judicial opinion by U.S....
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Whom Should You Suspend During an Internal FCPA Investigation?
Whom to suspend during any Foreign Corrupt Practices Act (FCPA) investigation is always a delicate question to answer. Unfortunately there is never an easy answer. As the Volkswagen (VW)...
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New Article: The Uncomfortable Truths and Double Standards of Bribery...
This article was reprinted with permission from FCPA ProfessorMy new article “The Uncomfortable Truths and Double Standards of Bribery Enforcement” will soon be published in the Fordham Law Review....
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Good-Bye to Maureen O’Hara and How to Drive Compliance Into the DNA of Your...
Maureen O’Hara died this week. To anyone who has ever watched The Quiet Man on St. Patrick’s Day, she will always be known as Mary Kate Danaher, who was pursued and eventually wed by John Wayne....
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Friday FCPA Roundup for Week Ending October 30
This article was reprinted with permission from FCPA ProfessorScrutiny alerts and updates, civil litigation updates, SEC enforcement statistics, and for the reading stack. It’s all here in the Friday...
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