Archiv der Kategorie: Compliance USA
FCPA: Six Steps to Implementing Continuous Monitoring in your Compliance Program
Anti-corruption, anti-bribery, anti-money laundering programs policies and procedures and even export control systems are seemingly in a constant state of evolution. Many companies are struggling with the challenge of implementing effective controls and monitoring risks across a spectrum that could … Weiterlesen
FCPA: What is the Role of a Board of Directors?
One of the ongoing topics for various Foreign Corrupt Practices Act (FCPA); UK Bribery Act or other anti-corruption and anti-bribery compliance conferences is what information does a Board of Directors want or need for oversight of a compliance program? However … Weiterlesen
FCPA: RAE and Settlement of FCPA Violations in China
As reported on Friday, December 10, 2010 in the FCPA Blog and by others, RAE Systems, Inc., (RAE) a California-based gas detection company settled Foreign Corrupt Practices Act (FCPA) charges on this date with the Department of Justice (DOJ) and … Weiterlesen
FCPA Enforcement: Why Corporations Support DPAs and NPAs
At the recent Dow Jones Global Compliance Symposium, there was a debate royal between Mark Mendelsohn and the FCPA Professor, Mike Koehler, regarding enforcement of the Foreign Corrupt Practices Act (FCPA). One of the points the Professor raised was regarding … Weiterlesen
FCPA: To Give or Not To Give and If So How, Under the FCPA
To give or not to give? That is certainly a question but it may also include the question of the value of the gift. Under the Foreign Corrupt Practices Act (FCPA) and UK Bribery Act gifts and entertainment continue to … Weiterlesen
The FCPA Enforcement Process: Negotiating the Penalty
I recently explored the issue of ‘extraordinary cooperation’ in the context of a Foreign Corrupt Practices Act (FCPA) enforcement proceeding and some of the concrete steps that a company could take to reduce its overall penalty assessed by the Department … Weiterlesen
Three Keys to the Role of a Chief Compliance Officer
There is an ongoing debate in the compliance world about whether a company can or should combine or separate the role of the Chief Compliance Officer (CCO) from that of the General Counsel (GC). However, before a company can answer … Weiterlesen
FCPA: 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 … Weiterlesen
FCPA: The BizJet DPA: Cooperation is the Key
Last week, the Department of Justice (DOJ) announced the resolution of an enforcement action under the Foreign Corrupt Practices Act (FCPA) involving the Tulsa based company, BizJet. The company is in the business of providing aircraft maintenance, repair and overhaul … Weiterlesen
FCPA: Creating Sustainable (Compliance) Performance
Compliance practitioners are continually tasked with moving a company’s culture of compliance forward. However, the day-to-day work is sometimes too granular to see results. In an article in the January-February issue of the Harvard Business Review, entitled “Creating Sustainable Performance”, … Weiterlesen
