Archiv der Kategorie: Compliance
How Do You Change a Corrupt Culture?
As most compliance practitioners know Siemens AG paid not only the largest Foreign Corrupt Practices Act (FCPA) fine in the history of the world at $800MM but also paid the same amount to the German government, this makes for a … Weiterlesen
Election Day – Just Who is a Foreign Government Official?
Ed. Note-we continue our series of guest posts from our colleague Mary Shaddock Jones, who today looks at the issue of foreign government officials under the FCPA. Both she and I urge you to exercise that most important right of … Weiterlesen
FCPA: The Five Essential Elements of a Corporate Compliance Program – Part II
Tuesday morning, at the University Club of Chicago, Stephen Martin and I will co-present at a Foreign Corrupt Practices Act (FCPA) event hosted by Kreller. If you are in or near Chicago, I hope that you can join us for … Weiterlesen
FCPA: The Five Essential Elements of a Corporate Compliance Program-Part I
Next Tuesday morning, at the University Club of Chicago, Stephen Martin and I will co-present at a Foreign Corrupt Practices Act (FCPA) event hosted by Kreller. If you are in or near Chicago I hope that you can join us. … Weiterlesen
FCPA: The Art of Strategic Compliance Plan – A Seven Step Process
I recently wrote about my colleague Stephen Martin’s thoughts on having a 1-3-5 year strategic plan for your company’s Foreign Corrupt Practices Act (FCPA) or Bribery Act compliance program. I am often asked where a compliance practitioner can come up … Weiterlesen
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
