FCPA compliance

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New Coke and Technological Solutions as a Response to the Economic Downturn

This might be the time that you consider a technological solution to help manage your FCPA anti-corruption compliance program going forward. It may be that you can come out running a more effective program, yet ultimately spend less money because you do not have to replace employees aid off during your company’s initial response to the downturn.

mcdonald's in russia

Franchising and Liability Under the FCPA

U.S. franchisors doing business abroad come into contact with officials of foreign governments fairly frequently - if not once they're up and running, then certainly during the startup process. Each interaction presents an opportunity for an FCPA violation. And if and when a misdeed comes to pass, who's ultimately liable? The individual with boots on the ...

DOJ

The Asia-Pacific Top 10 FCPA Enforcement Actions of 2014

FCPA enforcement has been on the rise of late, and several of the most significant enforcement actions taken in 2014 had connections to countries in the Asia-Pacific region. Wendy Wysong and her associates at Clifford Chance explore the largest and most impactful actions taken in the region this past year, with an analysis into the significance of each ...

trends-compressed

Top FCPA Enforcement Trends To Expect in 2015

The future is often a mystery, but here and there we're given insight into what's coming. FCPA authorities have done just that for us over the past few months, speaking often about their intentions for investigations and enforcement actions ahead. So instead of just guessing at what the landscape will look like this year, we can just ...

hagia sophia

Byzantium and the Alstom FCPA Settlement – Part III

The final installment from Tom Fox in a series on the Alstom FCPA enforcement action, this post explores the accounting records violations the French parent company owned up to. As it happens, the charges are a bit puzzling, but it's made clear in the settlement not only that there were some serious misdeeds afoot, but that there were ...

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Germany in the World Cup and the Alstom FCPA Enforcement Action – Part II

The recent Alstom enforcement action has dwarfed many others, and for Tom Fox, it brings to mind last summer's soccer upset heard 'round the world - Germany trouncing Brazil in the World Cup. Today's piece delves into the deferred prosecution agreements, outlining the requirements they set for Alstom and what they mean for compliance practitioners in general.

bookends

Book-Ending FCPA Compliance: The Importance of Risk Assessments and Monitoring

Risk assessments and monitoring are essential to any successful compliance program, and as such, they're the two key components FCPA enforcement officials look for when evaluating a company's compliance efforts. If either piece is absent, there will be serious doubt as to the company's commitment to compliance and, of course, to its ability to prevent and address violations.

alstom train

The Alstom FCPA Enforcement Action – Part I

The first in a series of posts from Tom Fox on the recent Alstom enforcement action -- among the very largest of all FCPA actions to date both in terms of the scope of the investigation and the amount of fines levied against the offending party. Lessons to be learned from Alstom? The importance of controls cannot ...