Schlagwort-Archive: Best Practices
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 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
The FCPA Enforcement Process: Negotiating the Penalty
I recently explored the issue of ‘extraordinary cooperation’ in the context of a Foreign Corrupt Practices Act (FCPA) enforcement proceeding and some of the concrete steps that a company could take to reduce its overall penalty assessed by the Department … Weiterlesen
