Archiv der Kategorie: Compliance USA
FCPA: The Dog Bite Defense and Your FCPA Compliance Program
As most readers of this blog know, I am a recovering trial lawyer. I almost always acted as defense counsel for corporations in my trial lawyer career. In the trial lawyer world, there are four recognized defenses to any claim … Weiterlesen
FCPA: Doomsayers Proven Wrong Yet Again-Gifts and Entertainment Under the Bribery Act
‘We are not interested in that sort of case. We are interested in hearing that a large company has mysteriously come second in bidding for a big contract. The sort of bribery we would be investigating would not be tickets … Weiterlesen
FCPA: How Do You Change an Unhealthy Compliance Culture?
Amüsant geschrieben und sehr lesenswert. What is a healthy culture and how do you change an unhealthy culture? I have always thought that baseball was a simple game: you throw the ball; you hit the ball; you catch the ball. … Weiterlesen
FCPA and Bribery Act Hotlines: Staying Out of Hot Water with Other Jurisdictions
It is finally here. Today is the Opening Ceremony of the Games of the XXX Olympiad in London. The first Olympics I can remember watching were the 1964 Games in Tokyo. I was enthralled with watching the world’s greatest athletes … Weiterlesen
Penn State, the Freeh Report and Implications for the FCPA Compliance Practitioner
The Freeh Report was released last week. It detailed a series of actions and inactions taken by officials at Penn State University (Penn State) which allowed Jerry Sandusky to continue his abuse of young boys from at least 1998 up … Weiterlesen
FCPA: Amendment to the Foreign Corrupt Practices Act – Another Perspective
Proposals for and against amending the Foreign Corrupt Practices Act, the US Federal law against government bribery in international business, have been percolating for the past 18 months. US Chamber of Commerce took a lead role, sponsoring a paper titled “Restoring Balance” … Weiterlesen
FCPA: This is not a compliance failure. It’s an ethical failure
In the movie “Margin Call” the character played by Jeremy Irons says that there are three ways to lead in business: (1) Be the smartest; (2) Be there first; (3) Cheat. I thought about this trichotomy when reading several articles … Weiterlesen
FCPA: Integrating Your Compliance Risk: Where the Rubber Meets the Road
In listening to companies discuss compliance in the areas of anti-corruption under the Foreign Corrupt Practices Act (FCPA), anti-money laundering (AML) or export control, one of the things that has consistently struck me is how siloed each of these groups … Weiterlesen
FCPA: Neither snow, nor rain, nor heat…Communicating Your Compliance Story
The Persian Royal Road was built to facilitate rapid communication throughout the Persian Empire. Mounted couriers could travel across the Empire, approximately 1,677 miles; in seven days, the equivalent journey on foot took ninety days. The Greek historian Herodotus wrote … Weiterlesen
FCPA: London Calling: The Olympics and Corporate Hospitality under the UK Bribery Act
As The Clash sang, London Calling, and the London Olympics are now less than 100 days away. One of the areas which has generated the greatest amount of hyperbole is over corporate hospitality at the upcoming 2012 summer Games. There … Weiterlesen
