Archiv der Kategorie: Compliance
COMPLIANCE TRAINING, PART I
In a recent Slate article, entitled “Ethics Trainings Are Even Dumber Than You Think”, author L.V. Anderson railed against what she termed box-checking training where companies put on training not to actually train employees but simply to check the box … Weiterlesen
Compliance Training – Part II: Risk Ranking and Design
Yesterday I began what I thought would be a two-part series on compliance training.However, or perhaps more accurately, as usual, I got carried away so I am now off on a multi-part series on how to design, implement and assess … Weiterlesen
Zur Auskunftspflicht des Geschäftsführers einer insolventen GmbH (BGH IX ZB 62/14, 05.03.2015)
Nach §§ 97, 101, 20 InsO ist der Geschäftsführer einer GmbH verpflichtet, dem Insolvenzgericht, dem Insolvenzverwalter, dem Gläubigerausschuss und u. U. auch der Gläubigerversammlung Auskunft über die wirtschaftlichen Verhältnisse und Geschäfte der insolventen Gesellschaft zu erteilen.
Managing Your Third Parties in a FCPA Compliance Program
The building blocks of any Foreign Corrupt Practices Act (FCPA) anti-corruption compliance program lay the foundations for a best practices compliance program.
Doing Less with Less and the Unification of Germany
I am attending the SCCE Utilities and Energy Conference in Houston this week. As usual, the SCCE has put on a great event for the compliance practitioner. This year there is live blogging by Kortney Nordum so there should be … Weiterlesen
Revisiting The Raven and Visiting Foreign Subsidiaries
On January 19 we celebrated the birth of one of America’s most iconic authors, Edgar Allen Poe, who was born on this day in Boston, Massachusetts. Anyone who reads or watches a mystery show on television owes a debt to … Weiterlesen
Hiring and Promotion in Compliance – Wait for Great
The role of Human Resources (HR) in anti-corruption programs, based upon the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act, is often underestimated.
Doing Business in India – Corruption Risks and Responses
Recently the US law firm of Foley and Lardner LLP and MZM Legal, Advocates & Legal Consultants in India jointly released a white paper, entitled “Anti-Bribery and Foreign Corrupt Practices Act Compliance Guide for U.S. Companies Doing Business in India”.
Due Diligence Going Forward in China
Whatever you might think of where his career went, Elton John had some great early stuff. I still rank Tumbleweed Connection right up there as one of my favorite albums of all-time. And while it was packed with some great … Weiterlesen
Does Your Company Still Allow Facilitation Payments?
One of the more confusing areas of the US Foreign Corrupt Practices Act (FCPA) is in that of facilitation payments. Facilitation payments are small bribes but make no mistake about it, they are bribes.