Many companies have an investigation protocol in place when a potential Foreign Corruption Practices Act (FCPA) or other legal issue arises. However, many Boards do not have the same rigor when it comes to an investigation, which should be conducted or led by the Board itself.
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The FCPA and Fight Against Terrorism
February 21, 2014
I admit it took me awhile to finally get it. I have long wondered what could have caused the explosion in DOJ and SEC enforcement of the Foreign Corrupt Practices Act (FCPA).
The Abbey Grange, the Quality of Justice and Codes of Conduct
February 5, 2014
In honor of the return of Sherlock to PBS with Season 3, I begin a week of Sherlockian-themed posts. Today we consider the quality of justice that Holmes discussed in The Abbey Grange…
Episode 2 of FCPA Training Series: Anti-Corruption Enforcement Across the Globe
January 29, 2014
The FCPA isn’t the only anti-corruption law. More than 70 countries have statutes against bribery or corrupting government officials. Tune into the next installment of Tom Fox’s FCPA training series…
Each Case is Unique – Drawing Lessons from Opinion Release 13-01
January 27, 2014
SEC and DOJ look at the facts and circumstances around each case in making assessments. While this is frustrating to business types, as a lawyer I find it to be an appropriate analysis, — and an accurate way to look at things.
Benedict Arnold and How To Be a Game Changer In Compliance
January 22, 2014
Last week marked the anniversary of the birth of one of the most notorious Americans of all time: Benedict Arnold. His name is synonymous with the word traitor in the United States and in many ways more derogatory.
Corruption in Turkey and Integrating Your Risk Assessment
January 17, 2014
One of the more public and ongoing corruption scandals in the world right now seems to be happening in Turkey. To say the events and facts are confused is an understatement.
Supermarket to the World – The ADM FCPA Enforcement Action
January 6, 2014
Last week, it was announced that the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) had settled an enforcement action with Archer-Daniels-Midland Company (ADM).
The Rogue Employee Myth: Prevention and Detection in a FCPA Compliance Program
December 18, 2013
I cannot think of any criminal enforcement actions against a corporation involving the Foreign Corrupt Practices Act (FCPA) where there was a lone wolf employee engaging in bribery and corruption on his or her own.
The Weatherford FCPA Settlement
December 10, 2013
In late November, Weatherford International Limited (Weatherford) concluded one of the longest running open Foreign Corrupt Practices Act (FCPA) investigations when it agreed to the ninth-largest FCPA fine of all-time and one of its subsidiaries, Weatherford Services Limited …
