Archiv der Kategorie: Compliance
FCPA: Internal Audit Review of Charitable Donations Under the FCPA
When is a rose not a rose? When it is a charitable donation not made for philanthropic purposes and it violates the Foreign Corrupt Practices Act (FCPA). I thought about that concept when reviewing the Eli Lilly and Company (Lilly) … Weiterlesen
FCPA: Top Ten Enforcement Actions for 2012
As we welcome in 2013, it is appropriate to reflect back on some of the things which have occurred over 2012 and in the Foreign Corrupt Practices Act (FCPA) enforcement world, it was quite a significant year. The Department of … Weiterlesen
FCPA: The CCO: Co-Equal to the General Counsel in the Eyes of the DOJ
One of the items that the Department of Justice (DOJ) has increasingly focused on in its enforcement actions is the role of the Chief Compliance Officer (CCO) and whether this position has adequate staffing and resources to accomplish its mandated … Weiterlesen
The FCPA Guidance and Declinations
I have previously written about my belief that the US Department of Justice (DOJ) should go further in releasing information about Declinations to Prosecute Foreign Corrupt Practices Act (FCPA) cases self-reported to both it and the Securities and Exchange Commission … Weiterlesen
FCPA: Using History to Create or Rebuild a Compliance Culture
I have wondered how organizations such as Siemens, Alcatel-Lucent or any others that have faced a wide-ranging, global charge of systemic bribery and corruption might change their culture. Many others have written about the structural changes that such companies have … Weiterlesen
The High Costs of Non-Compliance!
Ed Note-we continue our series of guest posts by Mary Jones. Today, Mary explores the high cost of non-compliance. On November 13, 1923 a special committee was formed to determine whether Germany would be required to pay for the substantial … Weiterlesen
The Red Scare: Knowledge and the Importance of Due Diligence
Ed. Note-we continue our series of guest posts from our colleague Mary Shaddock Jones, who today looks at the importance of due diligence. At midnight on November 9, 1989, East Germany’s rulers gave permission for the Berlin Wall, separating East … Weiterlesen
Wal-Mart Cover Up- Would a Hot-Line Have Helped?
Ed. Note-we continue our series of guest posts from our colleague Mary Shaddock Jones, who today draws some lessons from the Wal-Mart matter. On November 8, 2006 Wal-Mart entered the Canadian Market opening three supercenters in Ancaster, London and Stouffville … Weiterlesen
USA Recht. Resource Guide zum FCPA
Wichtig für Unternehmen, die in den USA Geschäfte machen. ThomsonReuters | Nov 15, 2012 DOJ gives glimpse of bribery cases it decided not to charge. U.S. officials have decided not to prosecute companies accused of bribing officials in foreign countries … Weiterlesen
Armistice Day: The Risks and Rewards of Foreign Joint Ventures
Ed. Note-we continue our series of guest posts from our colleague Mary Shaddock Jones, who today looks at Joint Ventures and has some pointers for avoiding pitfalls under the FCPA. In December 2010, RAE Systems Inc., a publicly-traded U.S. corporation … Weiterlesen
