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 …
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Mergers and Acquisitions Under the FCPA
December 2, 2013
Last year’s Foreign Corrupt Practices Act (FCPA) Guidance makes clear that one of the 10 hallmarks of an effective compliance program is around mergers and acquisitions (M&A), in both the pre and post-acquisition context.
Plato, Aristotle and Codes of Conduct
November 25, 2013
It was once observed that all western philosophy is but a mere footnote to the works of Plato. However, others believe that his student, Aristotle, merits equal standing. I recently read a review of the new book by Arthur Herman “The Cave and the Light” in the Wall Street Journal by reviewer Roger …
Of Prince-lings and Princess-lings – Does Their Employment Have Corrupt Intent?
November 20, 2013
There was an excellent article recently in the Financial Times (FT), entitled “Finance: Plugged Into the Party,” in which reporters Henry Sender and Tom Mitchell explored the hiring of sons and daughters of Chinese …
The Miami Dolphins – A Code Red for Compliance
November 15, 2013
I thought about the famous court scene in A Few Good Men while reading and hearing this week about the ongoing imbroglio inside the Miami Dolphins. For those of you who do not follow pro football, Jonathan Martin, an offensive lineman, left the team, allegedly due to the bullying and …
Reports Just In: Invasions from Mars and the UK Bribery Act
November 4, 2013
Seventy-five years ago Orson Welles caused a nationwide panic with his broadcast of “War of the Worlds.” Fortunately for us Americans, Welles’ show was just that – a dramatized radio show. Just as fortunately for us …
Wal-Mart: Be a Leader in Compliance
October 30, 2013
Lou Reed died Sunday. He was one of the most influential figures in rock and roll history and pop culture over the past 50 years and a true leader in many areas. Wal-Mart is well on its way to becoming the all-time leader in costs for an FCPA investigation. Here are my suggestions…
Pre-Acquisition Due Diligence Program for Evaluating Target Companies in M&A
October 24, 2013
I am just back from Washington, D.C., where I attended the SCCE 2013 annual Compliance & Ethics Institute and came away from one key session with five steps that you should take when looking at an acquisition from …
Be Relevant: How a Compliance Professional Can Influence Corporate Decision Making
October 14, 2013
So how do you influence decision making as a compliance professional? That topic was explored in a session at this year’s Society of Corporate Compliance and Ethics (SCCE) annual Compliance and Ethics Institute.
The Cost of Stupid is Less Than the Cost of Bribery and Corruption
October 9, 2013
As Forrest Gump might say, “Stupid is as stupid does.” But what might be some of the costs of allegations of bribery and corruption?
