Archiv der Kategorie: FCPA
Does Your Company Still Allow Facilitation Payments?
One of the more confusing areas of the US Foreign Corrupt Practices Act (FCPA) is in that of facilitation payments. Facilitation payments are small bribes but make no mistake about it, they are bribes.
Termination of a Third Party or Breaking Up Should Not Be Hard To Do
One of treats each month for the compliance professional is reading the GRC Illustrated column by Carole Switzer, President of the Open Compliance and Ethics Group (OCEG), in the Compliance Week magazine.
Code of Conduct, Compliance Policies and Procedures-Part IV
This is the fourth and final installment of my series on the the importance of a Code of Conduct and anti-corruption compliance policies and procedures in your compliance program and how you should go about drafting or updating Code of … Weiterlesen
Code of Conduct, Compliance Policies and Procedures-Part III
Today, I continue with Part III of my four-part series on the best practices surrounding your Code of Conduct and anti-corruption policies and procedures. In this post, I take a look at drafting policies and procedures. I conclude with some … Weiterlesen
Code of Conduct, Compliance Policies and Procedures-Part II
This week, I am reviewing the importance of a Code of Conduct and anti-corruption compliance policies and procedures in your compliance program and how you should go about drafting or updating Code of Conduct and anti-corruption compliance policies and procedures.
Looking Back on Johnny Winter and GSK’s 2001 China Bribery Scandal
Johnny Winter died yesterday. He was one of the greatest rock and roll guitarists of all-time. As posted in Rolling Stone’s online article “Johnny Winter, Texas Blues Guitar Icon, Dead at 70” by Kory Grow, Winter “was born in Beaumont, … Weiterlesen
Mergers and Acquisitions Under the FCPA, Part III
Today I conclude my three-part series on mergers and acquisitions under the Foreign Corrupt Practices Act (FCPA) with a review of the post-acquisition phase.
Mergers and Acquisitions Under the FCPA, Part II
Yesterday I began a three part series on mergers and acquisitions under the Foreign Corrupt Practices Act (FCPA). In Part I, I reviewed what you should accomplish in the pre-acquisition stage. Today I want to look at what you should … Weiterlesen
