Archiv der Kategorie: Compliance
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
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
