FCPA compliance

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FCPA Voluntary Disclosure Considerations

Technically, companies don't have to disclose FCPA violations. But the risk for not voluntarily disclosing corrupt behavior is great considering that wrongdoing may be found out anyway. Matteson Ellis poses several questions companies can contemplate when deciding whether self-disclosure is their best course of action, whatever the circumstances.

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Q&A with Richard Bistrong, the FCPA Blogger Who Knows

CCI's CEO, Maurice Gilbert, dives in with Richard Bistrong, a regular contributor at CCI and a former VP of International Sales who experienced firsthand a brush with the Law as a result of some missteps on the front line. Richard shares here a bit about his story - from the deeds themselves to getting caught, cooperating with law ...

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Tommy Lewis, Dicky Maegle and the DOJ Call for Individual Prosecutions

Acts of criminal misconduct are - almost without fail - carried out either by an individual or a group of individuals, so it stands to reason that the DOJ would focus its efforts on individual prosecutions rather than to bring charges against the company itself. The company's participation in any resulting investigation is expected, but it should tread ...

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Is the Paper Tiger Sharpening its Teeth?

In terms of FCPA enforcement, the UK's Serious Fraud Office doesn't hold a candle to the U.S. Department of Justice. Not yet, anyway. Over the past few months, it has become clear that the tide is turning; the SFO has several high-profile cases in the works and is seeking to extend its reach with an expanded arsenal ...

security

National Security and FCPA Investigations

The FCPA is one of many tools the DOJ and the SEC put to use in facilitating national security in the U.S. And while they are some of the largest players in protecting the nation's interests, compliance professionals working for global corporations also play a critical role in identifying vulnerabilities and doing serious due diligence to minimize risks.

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FCPA Enforcement: Where Have All the Enforcement Actions Gone?

With major FCPA investigations in the works, some of us are on pins and needles waiting for the enforcement actions to come down. But don't hold your breath... these investigations and their subsequent decisions take time. Years even. The fact that we've yet to see results of these investigations may be due to little else than ...

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More Empty Words for an FCPA Compliance Defense

Most compliance practitioners recognize that the FCPA compliance defense issue is very much a thing of the past, though some still advocate for it. The troubles with this approach are multiple. Michael Volkov outlines what's off about taking an FCPA compliance defense and why companies that take that route may come to regret it.

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Pro Football and the FCPA Professor

Ah, September: bringer of fall, sweater weather, and football. Compliance practitioners and lovers of football alike can appreciate the parallels between the sport and the nuts and bolts of FCPA compliance. The success of both teams relies heavily, for instance, on a strong understanding of the game plan. Tom Fox outlines a few other shared characteristics... ...