Archiv der Kategorie: Compliance
FCPA: From the Compact Model to the Luxury Model – Managing Your Third Party Risk
I am currently attending the Hanson Wade Oil and Gas Supply Chain Compliance conference in Houston. The event is excellent and the presentations have been ‘spot on’ for the nuts and bolts of how to do compliance. As the conference … Weiterlesen
FCPA: Money, Money, Money
I tried. I really tried. I tried not to rant about the Houston Astros during Spring Training, because as they say ‘hope springs eternal’ as all teams are tied at this point in the season (0-0). So when the Astros … Weiterlesen
FCPA: Distributors Should Be Analyzed As Any Other Third Party Representative in the Sales Chain
Ed. Note-David Simon is a partner at Foley and Lardner and Bill Athanas is a partner at Waller Lansden Dortch & Davis, LLP. Both have practices which include FCPA compliance. After my recent post on distributors under the FCPA, David and … Weiterlesen
FCPA: How to Introduce Change into Your FCPA Compliance Program (Without Blowing It Up)
Thucydides or Herodotus; Herodotus or Thucydides. Which is your favorite? I admit to vacillating between the two. Thucydides wrote about the end of the Athenian dynasty from the Peloponnesian War and the debacle of the Sicilian Invasion. Herodotus wrote about … Weiterlesen
FCPA: Doing Business In Italy-Step Up Your FCPA Compliance Now
Ed. Note-I met last week with Craig Bloom, a colleague who practices law in Houston. Craig, who is fluent in Italian, was telling me about some of the compliance issues that have been percolating in Italy and in Italian companies. … Weiterlesen
FCPA: Distributors under the FCPA
If there was ever a question that distributors were covered under the Foreign Corrupt Practices Act (FCPA), in 2012, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) made it emphatically clear that this class of entities in … Weiterlesen
Amnesty for Armstrong? Lessons for the Compliance Practitioner
The Lance Armstrong saga continues to provide many lessons for the compliance practitioner. A recent article on ESPN.com, entitled “Lance calls for amnesty program”, reported that Armstrong has come out in favor of those who openly speak about the doping … Weiterlesen
FCPA: Boeing and the Conduct of Due Diligence on Sub-Suppliers
The Foreign Corrupt Practices Act (FCPA) act has language which makes illegal a direct or indirect act which might be used to obtain or retain business from prohibited parties. This has caused companies to begin to look at their suppliers … Weiterlesen
FCPA: The FCPA Guidance on the Ten Hallmarks of an Effective Compliance Program
Many commentators are still mining the Department of Justice (DOJ)/Securities and Exchange Commission (SEC) publication, A Resource Guide to the U.S. Foreign Corrupt Practices Act, (the “Guidance”), which was released last November. I continue to find nuggets to provide to … Weiterlesen
FCPA: The HSBC AML Settlement – Lessons Learned for the AML Compliance Practitioner
I recently wrote about banks behaving badly. Currently, Exhibit A in that list is HSBC. In December, 2012, the UK banking giant HSBC agreed to pay a fine of $1.92 billion for its transgressions involving money laundering. Today I want … Weiterlesen
