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STEINMAN
As I look back over the FCPA developments from 2020, one thing stands out: the DOJ and SEC continue to demand robust compliance controls. In some cases, the agencies reinforced long-standing expectations, and severely punished companies that strayed from them –something old.In other cases, the
WHAT'S NEW ON THE FCPA TOP TEN LIST? What stands out on the FCPA Blog's list of the ten biggest FCPA cases of all time? There are two banks on the current top ten list -- Goldman Sachs is number one and SocGen is number ten. Telecoms occupy four spots on the list, the most for any industry group. Six of thetop ten cases date
AIRBUS PAYS $4 BILLION TO SETTLE GLOBAL BRIBERY AND TRADE Airbus SE paid $4 billion (€3.6 billion) to settle global bribery and trade charges with French, UK, and U.S. authorities Friday after an eight-year investigation triggered by a British whistleblower. Airbus paid French national prosecutor Parquet National Financier (PNF) about €2.1 billion ($2.POLICY BENCHMARK
Benchmarking Alert: Here’s Walmart’s full global anti-corruption policy. Harry Cassin May 12, 2021. In June 2019, Walmart paid the DOJ and SEC $282 million to settle allegations that it violated the FCPA by paying an intermediary in Brazil for help obtaining construction permits and having weak anti-corruption internal controls in Brazil AIRBUS SHATTERS THE FCPA TOP TEN Airbus SE smashed our top ten list Friday with a $2.09 billion FCPA settlement with the U.S. Department of Justice, sending it straight to number one. Airbus becomes the third French company to sit on the current top ten list, along with Alstom at $772 million and Société Générale at $585 millio CHINA’S PROPOSED DATA SECURITY AND PERSONAL INFORMATION Imminent changes to the legal landscape in China likely will further complicate investigations and litigation involving information stored in China. China recently released second drafts of its Data Security Law (DSL) and its Personal Information Protection Law WHERE'S THE HARM IN CONFLICTS OF INTEREST? There are many types of possible harm arising from conflicts of interest. Understanding what they are can be essential to developing effective policies, training, monitoring and other COI compliance measures. It can also be important to exercising informed judgment inthe
HOW TO RETRIEVE WORK-RELATED WHATSAPP MESSAGES IN A Unless a mobile device management (MDM) system or special software is in place, messages may not be retrievable without cooperation from custodians.Even with cooperation, old or deleted messages may be unobtainable. As employees increasingly work remotely — with work and private data merging on various apps and devices — employers are facing a very challenging issue: THE FCPA BLOGLISTSAT LARGEBE A SPONSORABOUTEDITORSIN THE NEWS The perception within many organizations is that a limited number of complaints being reported equals fewer problems. So it often becomes a conversation about the numbers. TOP TEN | THE FCPA BLOG Wall Street bank earns top spot on FCPA Blog top ten list. Harry Cassin October 26, 2020. Goldman Sachs Group Inc. shattered our top ten list with a $3.3 billion FCPA settlement with the U.S. Department of Justice and Securities and Exchange Commission, sending it straight to number one.. Continue Reading. THE FCPA IN 2020: NEW COMPLIANCE REQUIREMENTS SHAKEAUTHOR: BILLSTEINMAN
As I look back over the FCPA developments from 2020, one thing stands out: the DOJ and SEC continue to demand robust compliance controls. In some cases, the agencies reinforced long-standing expectations, and severely punished companies that strayed from them –something old.In other cases, the
WHAT'S NEW ON THE FCPA TOP TEN LIST? What stands out on the FCPA Blog's list of the ten biggest FCPA cases of all time? There are two banks on the current top ten list -- Goldman Sachs is number one and SocGen is number ten. Telecoms occupy four spots on the list, the most for any industry group. Six of thetop ten cases date
AIRBUS PAYS $4 BILLION TO SETTLE GLOBAL BRIBERY AND TRADE Airbus SE paid $4 billion (€3.6 billion) to settle global bribery and trade charges with French, UK, and U.S. authorities Friday after an eight-year investigation triggered by a British whistleblower. Airbus paid French national prosecutor Parquet National Financier (PNF) about €2.1 billion ($2.POLICY BENCHMARK
Benchmarking Alert: Here’s Walmart’s full global anti-corruption policy. Harry Cassin May 12, 2021. In June 2019, Walmart paid the DOJ and SEC $282 million to settle allegations that it violated the FCPA by paying an intermediary in Brazil for help obtaining construction permits and having weak anti-corruption internal controls in Brazil AIRBUS SHATTERS THE FCPA TOP TEN Airbus SE smashed our top ten list Friday with a $2.09 billion FCPA settlement with the U.S. Department of Justice, sending it straight to number one. Airbus becomes the third French company to sit on the current top ten list, along with Alstom at $772 million and Société Générale at $585 millio CHINA’S PROPOSED DATA SECURITY AND PERSONAL INFORMATION Imminent changes to the legal landscape in China likely will further complicate investigations and litigation involving information stored in China. China recently released second drafts of its Data Security Law (DSL) and its Personal Information Protection Law WHERE'S THE HARM IN CONFLICTS OF INTEREST? There are many types of possible harm arising from conflicts of interest. Understanding what they are can be essential to developing effective policies, training, monitoring and other COI compliance measures. It can also be important to exercising informed judgment inthe
HOW TO RETRIEVE WORK-RELATED WHATSAPP MESSAGES IN A Unless a mobile device management (MDM) system or special software is in place, messages may not be retrievable without cooperation from custodians.Even with cooperation, old or deleted messages may be unobtainable. As employees increasingly work remotely — with work and private data merging on various apps and devices — employers are facing a very challenging issue: AIRBUS SHATTERS THE FCPA TOP TEN Airbus SE smashed our top ten list Friday with a $2.09 billion FCPA settlement with the U.S. Department of Justice, sending it straight to number one. Airbus becomes the third French company to sit on the current top ten list, along with Alstom at $772 million and Société Générale at $585 millio CHINA’S PROPOSED DATA SECURITY AND PERSONAL INFORMATION Imminent changes to the legal landscape in China likely will further complicate investigations and litigation involving information stored in China. China recently released second drafts of its Data Security Law (DSL) and its Personal Information Protection Law WHY POST-M&A DECISIONS ARE DANGEROUS FOR COMPLIANCE Jennifer J. Fondrevay is the founder of Day1 Ready, an M&A consultancy focused on providing human capital strategies that retain deal value.A contributor to HBR, Fast Company, Inc. and Forbes, her best-selling book, Now What?A Survivor’s Guide for Thriving through Mergers & Acquisitions, guides executives and frontline leaders through the people challenges of business transformation to A COMPREHENSIVE ANTI-BRIBERY POLICY IS ESSENTIAL, BUT NOT A comprehensive anti-bribery policy is essential, but not enough. Klaus Moosmayer. April 13, 2021. 7:48 am. Recently, the FCPA Blog featured the Novartis anti-bribery policy as part of its respective benchmark series. The design and implementation of an effective anti-bribery policy is undoubtedly one of the pillars of every seriouscompliance
AMERICA: LET’S NOT PAT OURSELVES ON THE BACK QUITE YET Anti-corruption experts around the world cheered last week when the Biden Administration announced that “countering corruption a core United States national security interest.” And for good reason – the announcement identifies many of the issues that are criticalin
FORMER UK PROSECUTOR: DON'T GET CAUGHT IN AN ENDLESS CYCLE Corporate investigations initiated internally can be driven by two key factors: The need for a swift resolution, and the fear of external intervention either by a law enforcement or regulatory authority. The dominance of these two factors can mean that the investigation is conducted with a speci CAN YOU MEASURE A 'SPEAK-UP' CULTURE BY THE NUMBER OF The perception within many organizations is that a limited number of complaints being reported equals fewer problems. So it often becomes a conversation about the numbers. But do many complaints mean many problems, and do fewer complaints mean fewer problems? I suggest thatit's
WHICH COUNTRIES ARE THE MOST TRUSTWORTHY? Finland – 131. New Zealand – 137. Netherlands – 139. Australia – 170. Austria – 195. The United States trails the Top Ten at #20 with a total score of 369, and a poor showing on reputation, healthcare and safety. The following countries represent theMARTIN LØNSTRUP
Martin Lønstrup is Vice President, Compliance at Sandvik AB, a high-tech and global engineering group based in Sweden. He has worked in compliance for over 15 years in large international companies, building up compliance programs bringing experience from group compliance programs and operational compliance. He is passionate about working with ethics and culture. CHINA | THE FCPA BLOG News and commentary about white-collar crime, enforcement, andcompliance
TOP TEN | THE FCPA BLOG Wall Street bank earns top spot on FCPA Blog top ten list. Harry Cassin October 26, 2020. Goldman Sachs Group Inc. shattered our top ten list with a $3.3 billion FCPA settlement with the U.S. Department of Justice and Securities and Exchange Commission, sending it straight to number one.. Continue Reading. WHAT'S NEW ON THE FCPA TOP TEN LIST? What stands out on the FCPA Blog's list of the ten biggest FCPA cases of all time? There are two banks on the current top ten list -- Goldman Sachs is number one and SocGen is number ten. Telecoms occupy four spots on the list, the most for any industry group. Six of thetop ten cases date
WITH J&F, 2020 BECOMES THE BIGGEST YEAR IN FCPA HISTORY The first milestone: 2020 has officially become the largest year ever for FCPA settlements, with resolutions worth $2.94 billion. Falling to second place is 2019, with total settlements valued at $2.9 billion. So far in 2020, there have been nine FCPA corporate settlements, compared to fourteen in 2019. The second milestone: The J&F settlement DC BREEDS ANOTHER OUTRAGEOUS ETHICS SCANDAL DC breeds another outrageous ethics scandal. Jessica Tillipman. February 5, 2020. 7:38 am. Washington, D.C. has a long and ignominious history of local corruption scandals. So it takes uniquely outrageous conduct to capture the attention of my fellow Washingtonians. Jack Evans’ recent antics have managed to do just that. WHERE'S THE HARM IN CONFLICTS OF INTEREST? There are many types of possible harm arising from conflicts of interest. Understanding what they are can be essential to developing effective policies, training, monitoring and other COI compliance measures. It can also be important to exercising informed judgment inthe
COLLEGE SPORTS NEED MORE COMPLIANCE TEAMS College sports need more compliance teams. Ernesto J. Alvarado. May 29, 2020. 8:08 am. Universities have faced a series of unique challenges in the past several years, with the pandemic being the most recent. These institutions have also dealt with increasing scandals, such as the Varsity Blues and NCAA basketball corruption investigation DELL | THE FCPA BLOG Our latest BELA Executive Ethics and Compliance forum was co-hosted by Dell. We gathered more than a dozen compliance executives from top-performing companies to talk about why culture, training and risk management should be part of an SIEMENS | THE FCPA BLOG Richard L. Cassin September 23, 2016. The Federal Communications Commission fined Siemens Corporation and Siemens Medical Solutions $175,000 Thursday for failing to disclose corporate felony convictions as required by the FCC’s rules. Several Siemens companies hold FCC wireless licenses and were required to disclose on their applications HIRING | THE FCPA BLOG Qualcomm settles FCPA charges in princeling hiring case for $7.5 million. Richard L. Cassin March 1, 2016. The Securities and Exchange Commission said Tuesday that Qualcomm Incorporated agreed to pay $7.5 million to settle charges that it violated the Foreign Corrupt Practices Act by hiring relatives of Chinese government officials.. MICROSOFT PAYS $25 MILLION TO RESOLVE WIDESPREAD FCPA Microsoft Corporation paid the DOJ and SEC $25.3 million Monday to settle FCPA offenses related to its operations in Hungary, Saudi Arabia, Thailand, and Turkey. A Microsoft subsidiary in Hungary called Microsoft Magyarorszag Kft. paid a criminal penalty of $8.75 million and entered into a three-year non-prosecution agreement with the DOJ. TOP TEN | THE FCPA BLOG Wall Street bank earns top spot on FCPA Blog top ten list. Harry Cassin October 26, 2020. Goldman Sachs Group Inc. shattered our top ten list with a $3.3 billion FCPA settlement with the U.S. Department of Justice and Securities and Exchange Commission, sending it straight to number one.. Continue Reading. WHAT'S NEW ON THE FCPA TOP TEN LIST? What stands out on the FCPA Blog's list of the ten biggest FCPA cases of all time? There are two banks on the current top ten list -- Goldman Sachs is number one and SocGen is number ten. Telecoms occupy four spots on the list, the most for any industry group. Six of thetop ten cases date
WITH J&F, 2020 BECOMES THE BIGGEST YEAR IN FCPA HISTORY The first milestone: 2020 has officially become the largest year ever for FCPA settlements, with resolutions worth $2.94 billion. Falling to second place is 2019, with total settlements valued at $2.9 billion. So far in 2020, there have been nine FCPA corporate settlements, compared to fourteen in 2019. The second milestone: The J&F settlement DC BREEDS ANOTHER OUTRAGEOUS ETHICS SCANDAL DC breeds another outrageous ethics scandal. Jessica Tillipman. February 5, 2020. 7:38 am. Washington, D.C. has a long and ignominious history of local corruption scandals. So it takes uniquely outrageous conduct to capture the attention of my fellow Washingtonians. Jack Evans’ recent antics have managed to do just that. WHERE'S THE HARM IN CONFLICTS OF INTEREST? There are many types of possible harm arising from conflicts of interest. Understanding what they are can be essential to developing effective policies, training, monitoring and other COI compliance measures. It can also be important to exercising informed judgment inthe
COLLEGE SPORTS NEED MORE COMPLIANCE TEAMS College sports need more compliance teams. Ernesto J. Alvarado. May 29, 2020. 8:08 am. Universities have faced a series of unique challenges in the past several years, with the pandemic being the most recent. These institutions have also dealt with increasing scandals, such as the Varsity Blues and NCAA basketball corruption investigation DELL | THE FCPA BLOG Our latest BELA Executive Ethics and Compliance forum was co-hosted by Dell. We gathered more than a dozen compliance executives from top-performing companies to talk about why culture, training and risk management should be part of an SIEMENS | THE FCPA BLOG Richard L. Cassin September 23, 2016. The Federal Communications Commission fined Siemens Corporation and Siemens Medical Solutions $175,000 Thursday for failing to disclose corporate felony convictions as required by the FCC’s rules. Several Siemens companies hold FCC wireless licenses and were required to disclose on their applications HIRING | THE FCPA BLOG Qualcomm settles FCPA charges in princeling hiring case for $7.5 million. Richard L. Cassin March 1, 2016. The Securities and Exchange Commission said Tuesday that Qualcomm Incorporated agreed to pay $7.5 million to settle charges that it violated the Foreign Corrupt Practices Act by hiring relatives of Chinese government officials.. MICROSOFT PAYS $25 MILLION TO RESOLVE WIDESPREAD FCPA Microsoft Corporation paid the DOJ and SEC $25.3 million Monday to settle FCPA offenses related to its operations in Hungary, Saudi Arabia, Thailand, and Turkey. A Microsoft subsidiary in Hungary called Microsoft Magyarorszag Kft. paid a criminal penalty of $8.75 million and entered into a three-year non-prosecution agreement with the DOJ. HERBALIFE PAYS $123 MILLION TO RESOLVE CHINA FCPA OFFENSES Herbalife Nutrition Ltd. agreed Friday to pay the DOJ and SEC $123 million in penalties and disgorgement to resolve FCPA offenses in China. In an internal administrative order, the SEC charged Herbalife with violating the FCPA’s books and records and internal controls provisions.The U.S.-headquartered nutrition company agreed to disgorge $58.7 million plus prejudgment interest of $8.6 AIRBUS PAYS $4 BILLION TO SETTLE GLOBAL BRIBERY AND TRADE Airbus SE paid $4 billion (€3.6 billion) to settle global bribery and trade charges with French, UK, and U.S. authorities Friday after an eight-year investigation triggered by a British whistleblower. Airbus paid French national prosecutor Parquet National Financier (PNF) about €2.1 billion ($2. NOVARTIS PAYS $346.7 MILLION TO RESOLVE WIDESPREAD FCPA Pharmaceutical giant Novartis AG and two subsidiaries (one current and one former) agreed Thursday to pay the DOJ and SEC $346.7 million in penalties and disgorgement to resolve FCPA offenses in Greece, Vietnam, and South Korea. In an internal administrative order, the SEC charged Novartis AG wi DOJ CHARGES FORMER ALSTOM AND MARUBENI EXECS WITH FCPA DOJ charges former Alstom and Marubeni execs with FCPA offenses. The DOJ unsealed an indictment Tuesday against two former executives of Alstom S.A. and a former executive of the Japanese trading company Marubeni Corporation, for allegedly bribing the head of the state-owned power company in Indonesia and members of parliamentthere.
AMERICA: LET’S NOT PAT OURSELVES ON THE BACK QUITE YET Anti-corruption experts around the world cheered last week when the Biden Administration announced that “countering corruption a core United States national security interest.” And for good reason – the announcement identifies many of the issues that are criticalin
WORLD BANK DEBARS SOUTH ASIAN POWER The World Bank debarred an Indian power transmission company Wednesday for a year and a day for fraud involving projects in the Democratic Republic of the Congo and Egypt. During the debarment, Gujarat-based Kalpataru Power Transmission Ltd. (KPTL) and 12 global subsidiaries are ineligible to pa FORMER UK PROSECUTOR: DON'T GET CAUGHT IN AN ENDLESS CYCLE Corporate investigations initiated internally can be driven by two key factors: The need for a swift resolution, and the fear of external intervention either by a law enforcement or regulatory authority. The dominance of these two factors can mean that the investigation is conducted with a speci CAN YOU MEASURE A 'SPEAK-UP' CULTURE BY THE NUMBER OF The perception within many organizations is that a limited number of complaints being reported equals fewer problems. So it often becomes a conversation about the numbers. But do many complaints mean many problems, and do fewer complaints mean fewer problems? I suggest thatit's
MARTIN LØNSTRUP
Martin Lønstrup is Vice President, Compliance at Sandvik AB, a high-tech and global engineering group based in Sweden. He has worked in compliance for over 15 years in large international companies, building up compliance programs bringing experience from group compliance programs and operational compliance. He is passionate about working with ethics and culture. CHINA | THE FCPA BLOG News and commentary about white-collar crime, enforcement, andcompliance
TOP TEN | THE FCPA BLOG Wall Street bank earns top spot on FCPA Blog top ten list. Harry Cassin October 26, 2020. Goldman Sachs Group Inc. shattered our top ten list with a $3.3 billion FCPA settlement with the U.S. Department of Justice and Securities and Exchange Commission, sending it straight to number one.. Continue Reading. WHAT'S NEW ON THE FCPA TOP TEN LIST? What stands out on the FCPA Blog's list of the ten biggest FCPA cases of all time? There are two banks on the current top ten list -- Goldman Sachs is number one and SocGen is number ten. Telecoms occupy four spots on the list, the most for any industry group. Six of thetop ten cases date
WHY POST-M&A DECISIONS ARE DANGEROUS FOR COMPLIANCE Jennifer J. Fondrevay is the founder of Day1 Ready, an M&A consultancy focused on providing human capital strategies that retain deal value.A contributor to HBR, Fast Company, Inc. and Forbes, her best-selling book, Now What?A Survivor’s Guide for Thriving through Mergers & Acquisitions, guides executives and frontline leaders through the people challenges of business transformation to WITH J&F, 2020 BECOMES THE BIGGEST YEAR IN FCPA HISTORY The first milestone: 2020 has officially become the largest year ever for FCPA settlements, with resolutions worth $2.94 billion. Falling to second place is 2019, with total settlements valued at $2.9 billion. So far in 2020, there have been nine FCPA corporate settlements, compared to fourteen in 2019. The second milestone: The J&F settlement COLLEGE SPORTS NEED MORE COMPLIANCE TEAMS College sports need more compliance teams. Ernesto J. Alvarado. May 29, 2020. 8:08 am. Universities have faced a series of unique challenges in the past several years, with the pandemic being the most recent. These institutions have also dealt with increasing scandals, such as the Varsity Blues and NCAA basketball corruption investigation WHERE'S THE HARM IN CONFLICTS OF INTEREST? There are many types of possible harm arising from conflicts of interest. Understanding what they are can be essential to developing effective policies, training, monitoring and other COI compliance measures. It can also be important to exercising informed judgment inthe
DC BREEDS ANOTHER OUTRAGEOUS ETHICS SCANDAL DC breeds another outrageous ethics scandal. Jessica Tillipman. February 5, 2020. 7:38 am. Washington, D.C. has a long and ignominious history of local corruption scandals. So it takes uniquely outrageous conduct to capture the attention of my fellow Washingtonians. Jack Evans’ recent antics have managed to do just that. FOUR WAYS THE DOJ SIDESTEPS THE FCPA STATUTE OF Four ways the DOJ sidesteps the FCPA statute of limitations. In February, the Department of Justice unsealed an indictment against two former executives of the Indonesian subsidiary of Alstom S.A., Reza Moenaf and Eko Sulianto, and a former executive of Marubeni Corporation, Junji Kusunoki. Both companies pleaded guilty to foreignbribery
HIRING | THE FCPA BLOG Qualcomm settles FCPA charges in princeling hiring case for $7.5 million. Richard L. Cassin March 1, 2016. The Securities and Exchange Commission said Tuesday that Qualcomm Incorporated agreed to pay $7.5 million to settle charges that it violated the Foreign Corrupt Practices Act by hiring relatives of Chinese government officials.. MICROSOFT PAYS $25 MILLION TO RESOLVE WIDESPREAD FCPA Microsoft Corporation paid the DOJ and SEC $25.3 million Monday to settle FCPA offenses related to its operations in Hungary, Saudi Arabia, Thailand, and Turkey. A Microsoft subsidiary in Hungary called Microsoft Magyarorszag Kft. paid a criminal penalty of $8.75 million and entered into a three-year non-prosecution agreement with the DOJ. TOP TEN | THE FCPA BLOG Wall Street bank earns top spot on FCPA Blog top ten list. Harry Cassin October 26, 2020. Goldman Sachs Group Inc. shattered our top ten list with a $3.3 billion FCPA settlement with the U.S. Department of Justice and Securities and Exchange Commission, sending it straight to number one.. Continue Reading. WHAT'S NEW ON THE FCPA TOP TEN LIST? What stands out on the FCPA Blog's list of the ten biggest FCPA cases of all time? There are two banks on the current top ten list -- Goldman Sachs is number one and SocGen is number ten. Telecoms occupy four spots on the list, the most for any industry group. Six of thetop ten cases date
WHY POST-M&A DECISIONS ARE DANGEROUS FOR COMPLIANCE Jennifer J. Fondrevay is the founder of Day1 Ready, an M&A consultancy focused on providing human capital strategies that retain deal value.A contributor to HBR, Fast Company, Inc. and Forbes, her best-selling book, Now What?A Survivor’s Guide for Thriving through Mergers & Acquisitions, guides executives and frontline leaders through the people challenges of business transformation to WITH J&F, 2020 BECOMES THE BIGGEST YEAR IN FCPA HISTORY The first milestone: 2020 has officially become the largest year ever for FCPA settlements, with resolutions worth $2.94 billion. Falling to second place is 2019, with total settlements valued at $2.9 billion. So far in 2020, there have been nine FCPA corporate settlements, compared to fourteen in 2019. The second milestone: The J&F settlement COLLEGE SPORTS NEED MORE COMPLIANCE TEAMS College sports need more compliance teams. Ernesto J. Alvarado. May 29, 2020. 8:08 am. Universities have faced a series of unique challenges in the past several years, with the pandemic being the most recent. These institutions have also dealt with increasing scandals, such as the Varsity Blues and NCAA basketball corruption investigation WHERE'S THE HARM IN CONFLICTS OF INTEREST? There are many types of possible harm arising from conflicts of interest. Understanding what they are can be essential to developing effective policies, training, monitoring and other COI compliance measures. It can also be important to exercising informed judgment inthe
DC BREEDS ANOTHER OUTRAGEOUS ETHICS SCANDAL DC breeds another outrageous ethics scandal. Jessica Tillipman. February 5, 2020. 7:38 am. Washington, D.C. has a long and ignominious history of local corruption scandals. So it takes uniquely outrageous conduct to capture the attention of my fellow Washingtonians. Jack Evans’ recent antics have managed to do just that. FOUR WAYS THE DOJ SIDESTEPS THE FCPA STATUTE OF Four ways the DOJ sidesteps the FCPA statute of limitations. In February, the Department of Justice unsealed an indictment against two former executives of the Indonesian subsidiary of Alstom S.A., Reza Moenaf and Eko Sulianto, and a former executive of Marubeni Corporation, Junji Kusunoki. Both companies pleaded guilty to foreignbribery
HIRING | THE FCPA BLOG Qualcomm settles FCPA charges in princeling hiring case for $7.5 million. Richard L. Cassin March 1, 2016. The Securities and Exchange Commission said Tuesday that Qualcomm Incorporated agreed to pay $7.5 million to settle charges that it violated the Foreign Corrupt Practices Act by hiring relatives of Chinese government officials.. MICROSOFT PAYS $25 MILLION TO RESOLVE WIDESPREAD FCPA Microsoft Corporation paid the DOJ and SEC $25.3 million Monday to settle FCPA offenses related to its operations in Hungary, Saudi Arabia, Thailand, and Turkey. A Microsoft subsidiary in Hungary called Microsoft Magyarorszag Kft. paid a criminal penalty of $8.75 million and entered into a three-year non-prosecution agreement with the DOJ. AMERICA: LET’S NOT PAT OURSELVES ON THE BACK QUITE YET Anti-corruption experts around the world cheered last week when the Biden Administration announced that “countering corruption a core United States national security interest.” And for good reason – the announcement identifies many of the issues that are criticalin
THE FCPA IN 2020: NEW COMPLIANCE REQUIREMENTS SHAKE As I look back over the FCPA developments from 2020, one thing stands out: the DOJ and SEC continue to demand robust compliance controls. In some cases, the agencies reinforced long-standing expectations, and severely punished companies that strayed from them –something old.In other cases, the
FORMER UK PROSECUTOR: DON'T GET CAUGHT IN AN ENDLESS CYCLE Corporate investigations initiated internally can be driven by two key factors: The need for a swift resolution, and the fear of external intervention either by a law enforcement or regulatory authority. The dominance of these two factors can mean that the investigation is conducted with a speci NOVARTIS PAYS $346.7 MILLION TO RESOLVE WIDESPREAD FCPA Pharmaceutical giant Novartis AG and two subsidiaries (one current and one former) agreed Thursday to pay the DOJ and SEC $346.7 million in penalties and disgorgement to resolve FCPA offenses in Greece, Vietnam, and South Korea. In an internal administrative order, the SEC charged Novartis AG wi HERBALIFE PAYS $123 MILLION TO RESOLVE CHINA FCPA OFFENSES Herbalife Nutrition Ltd. agreed Friday to pay the DOJ and SEC $123 million in penalties and disgorgement to resolve FCPA offenses in China. In an internal administrative order, the SEC charged Herbalife with violating the FCPA’s books and records and internal controls provisions.The U.S.-headquartered nutrition company agreed to disgorge $58.7 million plus prejudgment interest of $8.6 AIRBUS PAYS $4 BILLION TO SETTLE GLOBAL BRIBERY AND TRADE Airbus SE paid $4 billion (€3.6 billion) to settle global bribery and trade charges with French, UK, and U.S. authorities Friday after an eight-year investigation triggered by a British whistleblower. Airbus paid French national prosecutor Parquet National Financier (PNF) about €2.1 billion ($2. CAN YOU MEASURE A 'SPEAK-UP' CULTURE BY THE NUMBER OF The perception within many organizations is that a limited number of complaints being reported equals fewer problems. So it often becomes a conversation about the numbers. But do many complaints mean many problems, and do fewer complaints mean fewer problems? I suggest thatit's
WORLD BANK DEBARS SOUTH ASIAN POWER TRANSMISSION COMPANY The World Bank debarred an Indian power transmission company Wednesday for a year and a day for fraud involving projects in the Democratic Republic of the Congo and Egypt. During the debarment, Gujarat-based Kalpataru Power Transmission Ltd. (KPTL) and 12 global subsidiaries are ineligible to paSPEAK-UP CULTURE
News and commentary about white-collar crime, enforcement, andcompliance
HIRING | THE FCPA BLOG Qualcomm settles FCPA charges in princeling hiring case for $7.5 million. Richard L. Cassin March 1, 2016. The Securities and Exchange Commission said Tuesday that Qualcomm Incorporated agreed to pay $7.5 million to settle charges that it violated the Foreign Corrupt Practices Act by hiring relatives of Chinese government officials.. THE FCPA BLOGLISTSAT LARGEBE A SPONSORABOUTEDITORSIN THE NEWS Halfway through the first-ever United Nations General Assembly Special Session on corruption, the White House announced a new initiative: a comprehensive national security strategy to combat corruption. A memo from President Biden specifically named partnership with the private sector as a core tenet. TOP TEN | THE FCPA BLOG Wall Street bank earns top spot on FCPA Blog top ten list. Harry Cassin October 26, 2020. Goldman Sachs Group Inc. shattered our top ten list with a $3.3 billion FCPA settlement with the U.S. Department of Justice and Securities and Exchange Commission, sending it straight to number one.. Continue Reading. WHAT'S NEW ON THE FCPA TOP TEN LIST? What stands out on the FCPA Blog's list of the ten biggest FCPA cases of all time? There are two banks on the current top ten list -- Goldman Sachs is number one and SocGen is number ten. Telecoms occupy four spots on the list, the most for any industry group. Six of thetop ten cases date
THE FCPA IN 2020: NEW COMPLIANCE REQUIREMENTS SHAKEAUTHOR: BILLSTEINMAN
As I look back over the FCPA developments from 2020, one thing stands out: the DOJ and SEC continue to demand robust compliance controls. In some cases, the agencies reinforced long-standing expectations, and severely punished companies that strayed from them –something old.In other cases, the
WHERE'S THE HARM IN CONFLICTS OF INTEREST? There are many types of possible harm arising from conflicts of interest. Understanding what they are can be essential to developing effective policies, training, monitoring and other COI compliance measures. It can also be important to exercising informed judgment inthe
HOW TO RETRIEVE WORK-RELATED WHATSAPP MESSAGES IN A Unless a mobile device management (MDM) system or special software is in place, messages may not be retrievable without cooperation from custodians.Even with cooperation, old or deleted messages may be unobtainable. As employees increasingly work remotely — with work and private data merging on various apps and devices — employers are facing a very challenging issue: SIEMENS | THE FCPA BLOG Richard L. Cassin September 23, 2016. The Federal Communications Commission fined Siemens Corporation and Siemens Medical Solutions $175,000 Thursday for failing to disclose corporate felony convictions as required by the FCC’s rules. Several Siemens companies hold FCC wireless licenses and were required to disclose on their applications FOUR WAYS THE DOJ SIDESTEPS THE FCPA STATUTE OF Four ways the DOJ sidesteps the FCPA statute of limitations. In February, the Department of Justice unsealed an indictment against two former executives of the Indonesian subsidiary of Alstom S.A., Reza Moenaf and Eko Sulianto, and a former executive of Marubeni Corporation, Junji Kusunoki. Both companies pleaded guilty to foreignbribery
THAT'S NO BRIBE, IT'S RANSOM MONEY That’s no bribe, it’s ransom money. Richard L. Cassin. January 9, 2013. 9:28 am. Companies often face extortionate demands from foreign police, bureaucrats, and regulators, who threaten to hold, expel, or even harm employees if ransoms aren’t paid. And there have always been questions whether those involuntary payments can violate theFCPA.
DR. KING: BEFORE YOU FINISH BREAKFAST, YOU'VE DEPENDED ON There was so much to admire in Martin Luther King -- his courage, his faith, and his humility all come to mind. But by any measure, one of his most remarkable traits was an ability to see the way life intersects, how each of us depends on a far-flung legion every dayjust to survive.
THE FCPA BLOGLISTSAT LARGEBE A SPONSORABOUTEDITORSIN THE NEWS Halfway through the first-ever United Nations General Assembly Special Session on corruption, the White House announced a new initiative: a comprehensive national security strategy to combat corruption. A memo from President Biden specifically named partnership with the private sector as a core tenet. TOP TEN | THE FCPA BLOG Wall Street bank earns top spot on FCPA Blog top ten list. Harry Cassin October 26, 2020. Goldman Sachs Group Inc. shattered our top ten list with a $3.3 billion FCPA settlement with the U.S. Department of Justice and Securities and Exchange Commission, sending it straight to number one.. Continue Reading. WHAT'S NEW ON THE FCPA TOP TEN LIST? What stands out on the FCPA Blog's list of the ten biggest FCPA cases of all time? There are two banks on the current top ten list -- Goldman Sachs is number one and SocGen is number ten. Telecoms occupy four spots on the list, the most for any industry group. Six of thetop ten cases date
THE FCPA IN 2020: NEW COMPLIANCE REQUIREMENTS SHAKEAUTHOR: BILLSTEINMAN
As I look back over the FCPA developments from 2020, one thing stands out: the DOJ and SEC continue to demand robust compliance controls. In some cases, the agencies reinforced long-standing expectations, and severely punished companies that strayed from them –something old.In other cases, the
WHERE'S THE HARM IN CONFLICTS OF INTEREST? There are many types of possible harm arising from conflicts of interest. Understanding what they are can be essential to developing effective policies, training, monitoring and other COI compliance measures. It can also be important to exercising informed judgment inthe
HOW TO RETRIEVE WORK-RELATED WHATSAPP MESSAGES IN A Unless a mobile device management (MDM) system or special software is in place, messages may not be retrievable without cooperation from custodians.Even with cooperation, old or deleted messages may be unobtainable. As employees increasingly work remotely — with work and private data merging on various apps and devices — employers are facing a very challenging issue: SIEMENS | THE FCPA BLOG Richard L. Cassin September 23, 2016. The Federal Communications Commission fined Siemens Corporation and Siemens Medical Solutions $175,000 Thursday for failing to disclose corporate felony convictions as required by the FCC’s rules. Several Siemens companies hold FCC wireless licenses and were required to disclose on their applications FOUR WAYS THE DOJ SIDESTEPS THE FCPA STATUTE OF Four ways the DOJ sidesteps the FCPA statute of limitations. In February, the Department of Justice unsealed an indictment against two former executives of the Indonesian subsidiary of Alstom S.A., Reza Moenaf and Eko Sulianto, and a former executive of Marubeni Corporation, Junji Kusunoki. Both companies pleaded guilty to foreignbribery
THAT'S NO BRIBE, IT'S RANSOM MONEY That’s no bribe, it’s ransom money. Richard L. Cassin. January 9, 2013. 9:28 am. Companies often face extortionate demands from foreign police, bureaucrats, and regulators, who threaten to hold, expel, or even harm employees if ransoms aren’t paid. And there have always been questions whether those involuntary payments can violate theFCPA.
DR. KING: BEFORE YOU FINISH BREAKFAST, YOU'VE DEPENDED ON There was so much to admire in Martin Luther King -- his courage, his faith, and his humility all come to mind. But by any measure, one of his most remarkable traits was an ability to see the way life intersects, how each of us depends on a far-flung legion every dayjust to survive.
CHINA’S PROPOSED DATA SECURITY AND PERSONAL INFORMATION Imminent changes to the legal landscape in China likely will further complicate investigations and litigation involving information stored in China. China recently released second drafts of its Data Security Law (DSL) and its Personal Information Protection Law NOVARTIS PAYS $346.7 MILLION TO RESOLVE WIDESPREAD FCPA Pharmaceutical giant Novartis AG and two subsidiaries (one current and one former) agreed Thursday to pay the DOJ and SEC $346.7 million in penalties and disgorgement to resolve FCPA offenses in Greece, Vietnam, and South Korea. In an internal administrative order, the SEC charged Novartis AG wi HOW DO YOU CALCULATE FCPA SETTLEMENT AMOUNTS? In Telia’s case, the total FCPA settlement about would be: $548.6 million + $457 million = $1.01 billion. Finding the exact settlement amount of an FCPA corporate resolution is not always straightforward, and there are many different ways to do the math. This is how the FCPA Blog calculates FCPA-related settlement amounts, and we aim to stay FIGHTING CORRUPTION IS NOW A U.S. NATIONAL SECURITY Halfway through the first-ever United Nations General Assembly Special Session on corruption, the White House announced a new initiative: a comprehensive national security strategy to combat corruption. A memo from President Biden specifically named partnership with the privatesector as
HERBALIFE PAYS $123 MILLION TO RESOLVE CHINA FCPA OFFENSES Herbalife Nutrition Ltd. agreed Friday to pay the DOJ and SEC $123 million in penalties and disgorgement to resolve FCPA offenses in China. In an internal administrative order, the SEC charged Herbalife with violating the FCPA’s books and records and internal controls provisions.The U.S.-headquartered nutrition company agreed to disgorge $58.7 million plus prejudgment interest of $8.6 AMERICA: LET’S NOT PAT OURSELVES ON THE BACK QUITE YET Anti-corruption experts around the world cheered last week when the Biden Administration announced that “countering corruption a core United States national security interest.” And for good reason – the announcement identifies many of the issues that are criticalin
FORMER UK PROSECUTOR: DON'T GET CAUGHT IN AN ENDLESS CYCLE Corporate investigations initiated internally can be driven by two key factors: The need for a swift resolution, and the fear of external intervention either by a law enforcement or regulatory authority. The dominance of these two factors can mean that the investigation is conducted with a speci CAN YOU MEASURE A 'SPEAK-UP' CULTURE BY THE NUMBER OF The perception within many organizations is that a limited number of complaints being reported equals fewer problems. So it often becomes a conversation about the numbers. But do many complaints mean many problems, and do fewer complaints mean fewer problems? I suggest thatit's
VERA CHEREPANOVA
Vera Cherepanova, FCCA, CIA, MSc, has more than 10 years' experience as a compliance officer. She's the founder of Studio Etica, a boutique consultancy that provides advice on corporate ethics and compliance programs to companies around the world.SPEAK-UP CULTURE
News and commentary about white-collar crime, enforcement, andcompliance
THE FCPA BLOGLISTSAT LARGEBE A SPONSORABOUTEDITORSIN THE NEWS The ethics and compliance e-learning series, Compliance Corner, has won a Silver Telly award for Corporate Training, honoring excellence in video and television content across all screens. Continue Reading TOP TEN | THE FCPA BLOG We’ve tabulated all countries reported in connection with the ten enforcement actions that comprise the latest FCPA Blog Top Ten list. Twenty-six different countries appear. DC BREEDS ANOTHER OUTRAGEOUS ETHICS SCANDAL Washington, D.C. has a long and ignominious history of local corruption scandals. So it takes uniquely outrageous conduct to capture the attention of my fellow Washingtonians. Jack Evans’ recent antics have managed to do just that. First, a little background. Jack Evans was the HOW DO YOU CALCULATE FCPA SETTLEMENT AMOUNTS? In January, Airbus entered into a $4 billion global settlement to resolve bribery offenses. Why did the FCPA Blog assess Airbus' FCPA penalty at about half that number for the top ten list? When calculating FCPA-related settlement amounts, we use the following guidelines: The total monetary WORLD BANK DEBARS SOUTH ASIAN POWER The World Bank debarred an Indian power transmission company Wednesday for a year and a day for fraud involving projects in the Democratic Republic of the Congo and Egypt. During the debarment, Gujarat-based Kalpataru Power Transmission Ltd. (KPTL) and 12 global subsidiaries are ineligible to pa COLLEGE SPORTS NEED MORE COMPLIANCE TEAMS Universities have faced a series of unique challenges in the past several years, with the pandemic being the most recent. These institutions have also dealt with increasing scandals, such as the Varsity Blues and NCAA basketball corruption investigation, which suggest more attention is needed on WHERE'S THE HARM IN CONFLICTS OF INTEREST? There are many types of possible harm arising from conflicts of interest. Understanding what they are can be essential to developing effective policies, training, monitoring and other COI compliance measures. It can also be important to exercising informed judgment inthe
WHICH COUNTRIES ARE THE MOST TRUSTWORTHY? Barbara Brooks Kimmel is the CEO and Cofounder of Trust Across America-Trust Around the World whose mission is to help organizations build trust. She also runs the world’s largest global Trust Alliance and is the editor of the award-winning TRUST INC. book series. DEUTSCHE BANK PAYS SEC $16 MILLION TO SETTLE ‘REFERRAL Deutsche Bank paid the SEC $16 million Thursday to settle FCPA offenses related to its hiring of relatives of public officials inChina and Russia.
FINCEN FINES PACIFIC ISLAND CASINO $75 MILLION FOR Image courtesy of the Tinian Dynasty The Financial Crimes Enforcement Network (FinCEN) fined a Northern Mariana Islands casino $75 million Wednesday “for willful and egregious violations of the Bank Secrecy Act (BSA).”. Hong Kong Entertainment (Overseas) Investments, Ltd., doing business as the Tinian Dynasty Hotel & Casino, had no anti-moneylaundering program.
THE FCPA BLOGLISTSAT LARGEBE A SPONSORABOUTEDITORSIN THE NEWS The ethics and compliance e-learning series, Compliance Corner, has won a Silver Telly award for Corporate Training, honoring excellence in video and television content across all screens. Continue Reading TOP TEN | THE FCPA BLOG We’ve tabulated all countries reported in connection with the ten enforcement actions that comprise the latest FCPA Blog Top Ten list. Twenty-six different countries appear. DC BREEDS ANOTHER OUTRAGEOUS ETHICS SCANDAL Washington, D.C. has a long and ignominious history of local corruption scandals. So it takes uniquely outrageous conduct to capture the attention of my fellow Washingtonians. Jack Evans’ recent antics have managed to do just that. First, a little background. Jack Evans was the HOW DO YOU CALCULATE FCPA SETTLEMENT AMOUNTS? In January, Airbus entered into a $4 billion global settlement to resolve bribery offenses. Why did the FCPA Blog assess Airbus' FCPA penalty at about half that number for the top ten list? When calculating FCPA-related settlement amounts, we use the following guidelines: The total monetary WORLD BANK DEBARS SOUTH ASIAN POWER The World Bank debarred an Indian power transmission company Wednesday for a year and a day for fraud involving projects in the Democratic Republic of the Congo and Egypt. During the debarment, Gujarat-based Kalpataru Power Transmission Ltd. (KPTL) and 12 global subsidiaries are ineligible to pa COLLEGE SPORTS NEED MORE COMPLIANCE TEAMS Universities have faced a series of unique challenges in the past several years, with the pandemic being the most recent. These institutions have also dealt with increasing scandals, such as the Varsity Blues and NCAA basketball corruption investigation, which suggest more attention is needed on WHERE'S THE HARM IN CONFLICTS OF INTEREST? There are many types of possible harm arising from conflicts of interest. Understanding what they are can be essential to developing effective policies, training, monitoring and other COI compliance measures. It can also be important to exercising informed judgment inthe
WHICH COUNTRIES ARE THE MOST TRUSTWORTHY? Barbara Brooks Kimmel is the CEO and Cofounder of Trust Across America-Trust Around the World whose mission is to help organizations build trust. She also runs the world’s largest global Trust Alliance and is the editor of the award-winning TRUST INC. book series. DEUTSCHE BANK PAYS SEC $16 MILLION TO SETTLE ‘REFERRAL Deutsche Bank paid the SEC $16 million Thursday to settle FCPA offenses related to its hiring of relatives of public officials inChina and Russia.
FINCEN FINES PACIFIC ISLAND CASINO $75 MILLION FOR Image courtesy of the Tinian Dynasty The Financial Crimes Enforcement Network (FinCEN) fined a Northern Mariana Islands casino $75 million Wednesday “for willful and egregious violations of the Bank Secrecy Act (BSA).”. Hong Kong Entertainment (Overseas) Investments, Ltd., doing business as the Tinian Dynasty Hotel & Casino, had no anti-moneylaundering program.
WHAT'S NEW ON THE FCPA TOP TEN LIST? What stands out on the FCPA Blog's list of the ten biggest FCPA cases of all time? There are two banks on the current top ten list -- Goldman Sachs is number one and SocGen is number ten. Telecoms occupy four spots on the list, the most for any industry group. Six of thetop ten cases date
FIGHTING CORRUPTION IS NOW A U.S. NATIONAL SECURITY 15 hours ago · Halfway through the first-ever United Nations General Assembly Special Session on corruption, the White House announced a new initiative: a comprehensive national security strategy to combat corruption. A memo from President Biden specifically named partnership with the private sector as HOW DO YOU CALCULATE FCPA SETTLEMENT AMOUNTS? In January, Airbus entered into a $4 billion global settlement to resolve bribery offenses. Why did the FCPA Blog assess Airbus' FCPA penalty at about half that number for the top ten list? When calculating FCPA-related settlement amounts, we use the following guidelines: The total monetary LANDING | FCPA BLOG+ Welcome to FCPA Blog+ Compliance resources for professionals Complete FCPA Corporate Enforcement Index Every corporate enforcement action from the FCPA's beginning until today. Instantly sort using a single filter, or a combination of filters. It's seriously fast. FCPAcorporate enforc
TELLY AWARDS
The ethics and compliance e-learning series, Compliance Corner, has won a Silver Telly award for Corporate Training, honoring excellence in video and television content across all screens. Continue Reading SIEMENS | THE FCPA BLOG During the second calendar quarter — amid the Covid-19 lockdown — there were two corporate FCPA enforcement actions. For comparison, during the second calendar quarter last year, there were three corporate FCPA enforcement actions, and during Q2 2018, there were five corporate FCPA enforcement actions. AIRBUS PAYS $4 BILLION TO SETTLE GLOBAL BRIBERY AND TRADE Airbus SE paid $4 billion (€3.6 billion) to settle global bribery and trade charges with French, UK, and U.S. authorities Friday after an eight-year investigation triggered by a British whistleblower. Airbus paid French national prosecutor Parquet National Financier (PNF) about €2.1 billion ($2. GENERAL ASSEMBLY SPECIAL SESSION News and commentary about white-collar crime, enforcement, andcompliance
SAPIN II | THE FCPA BLOG The French Anti-Corruption Agency (AFA) has just published the English version of its revised anti-corruption compliance Guidelines. Reflecting three years of experience in implementing France’s landmark Sapin II law, the Guidelines lay out the agency’s recommendations for both the public and private sectors. WHICH COUNTRIES ARE THE MOST TRUSTWORTHY? Barbara Brooks Kimmel is the CEO and Cofounder of Trust Across America-Trust Around the World whose mission is to help organizations build trust. She also runs the world’s largest global Trust Alliance and is the editor of the award-winning TRUST INC. book series.Skip to content
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CAN ANTI-BRIBERY ENFORCEMENT HEAL SOCIAL WOUNDS? Andy Spalding June 1, 2020 Writing today from Richmond, Virginia – again the site of racial justice protest — I argue that anti-bribery enforcement can heal social wounds, and must.… Continue Reading COLLEGE SPORTS NEED MORE COMPLIANCE TEAMS Ernesto J. Alvarado May 29, 2020 Universities have faced a series of unique challenges in the past several years, with the pandemic being the most recent. These institutions have also dealt with increasing scandals, such as the Varsity Blues and NCAA basketball corruption investigation, which suggest more attention is needed on compliance matters.… ContinueReading
AT LARGE: IT’S TIME TO HAVE ‘THE TALK’ WITH YOUR BOSS ABOUTSUCCESSOR LIABILITY
Richard L. Cassin May 28, 2020 Two very different groups of companies will emerge from the lockdown: thousands with liquidity problems and uncertain futures, and hundreds with piles of cash and an appetite for growth. That means there’s a coming surge in mergers and acquisitions.… Continue Reading FORMER UK PROSECUTOR: WORK FROM HOME OPTIONS TRIGGER NEW INTERNALCOMPLIANCE CONCERNS
Lloydette Bai-Marrow May 27, 2020 As the lockdown is slowly lifted, it’s becoming clear that workers aren’t going to rush back to their offices. Some will eventually return, but for others, working from home will be more or less permanent.… Continue Reading JOB: CORPORATE COMPLIANCE COUNSEL (ANTI-BRIBERY AND CORRUPTION) The FCPA Blog May 26, 2020 Job Title: Corporate Compliance Counsel (Anti-bribery and Corruption) Employer: Macquarie Group Limited Location: New York, New York USA… Continue Reading WHEN WILL PROSECUTORS IDENTIFY AND COMPENSATE OVERSEAS VICTIMS OFCORRUPTION?
Genevieve Theriault-Lachance May 26, 2020 Identifying and compensating overseas victims of corruption is a major challenge that prosecutors have yet to adequately address. As Jeffrey Kaplan recently discussed in a post for the FCPA Blog, when corruption is treated as victimless, it may allow those involved in the crime to “feel comfortable with their participation.”… Continue Reading ANTI-GRAFT REFORM LIFTS ASIA, TEMPERED BY POLITICAL RISK John Bray May 22, 2020 As Jason Deegan’s postfor
the FCPA Blog recently reminded us, Transparency International’s Corruption Perceptions Index (CPI) rarely points to major changes from year to year. However, a closer analysis of ratings since 2012 – the year when TI adopted its current methodology for the CPI – may be more revealing.… Continue Reading AT LARGE: OFAC CREATES TITANIC PROBLEM FOR COMPLIANCE CHIEFS Richard L. Cassin May 21, 2020 Amid the coming post-Covid-19 resizing wave, when chief compliance officers request _bigger_ budgets, don’t laugh, and don’t blame them. This time, it’s OFAC’s fault.… Continue Reading JOB: CHIEF ETHICS & COMPLIANCE OFFICER The FCPA Blog May 20, 2020 Job Title: Chief Ethics & Compliance Officer Employer: Mercy Corps Location: Portland, Oregon, Washington, D.C., or London, UK.…Continue Reading
NEW BRAZIL BANK REGULATIONS REQUIRE SIGNIFICANT COMPLIANCE CHANGES Fabiana Muniz Lima May 20, 2020 In October, new regulations from the Brazilian Central Bank will go into effect targetingthe
prevention of the use of the financial system for money laundering, terrorist financing, the proliferation of weapons of mass destruction, and suspicious transaction reporting.… Continue Reading IS NIGERIA TURNING AROUND ITS ANTI-CORRUPTION ENFORCEMENT? Matthew T. Page May 19, 2020 Nigeria’s anti-corruption law enforcement efforts are gradually growing more effective as practitioners adapt and innovate in response to many persistent challenges. Sometimes caricatured as sclerotic, politicized, or error-prone, high-level anti-corruption efforts are becoming noticeably more innovative and pragmatic.… Continue Reading THE U.S. HAS A CHANCE TO TARGET DEMAND-SIDE BRIBERY WITH THE CROOKACT
Alexandra Wrage May 18, 2020 Companies have long complained, rightly, that they bear the brunt of most anti-bribery efforts. Bribes are, at their simplest, transactions between two parties, but companies are prosecuted aggressively while the misconduct by grasping government officials typically escapes notice, or at least prosecution.… Continue Reading Previous Page1 Page2 Page3… Page642
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