FCPA enforcement

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The 10 Most Important FCPA Internal Controls (Part One: Accounting Controls)

Under the FCPA, companies can be punished not only for the wrongful things they do, like paying bribes, but also for certain things they don’t do. In particular, the FCPA’s accounting provisions require companies to have internal controls in place. When companies do not have certain protections, such as appropriate accounting systems and anti-corruption policies, procedures and processes, ...

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The Battle of Shiloh, Corruption in Ukraine and Things to Come

Monday marked the 126th anniversary of the ending of the the two-day battle of Shiloh. On the second day, the Union troops under General Grant largely recovered the ground that the Confederate troops had taken on the first day. Grant was severely criticized for allegedly being taken by surprise by the Confederate attack, but he managed to survive the ...

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FCPA Year in Review 2013, Part 2

As demonstrated below, the sentences handed down in 2013 were a mixed bag, and (except for Frederic Bourke) all individuals cooperated with the government to some extent.

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Harriet Tubman and Navigating to Become an Ethical Company

March 10th was the 101st anniversary of the death of Harriet Tubman. She was one of the greatest conductors on the Underground Railroad, which took slaves out of the old south and up to freedom in the north and into Canada. I read about her as a child and her story always moved me.

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FCPA Year in Review 2013, Part 1

Foreign Corrupt Practices Act (FCPA) enforcement activity in 2013 was robust, with the DOJ and SEC bringing 31 new FCPA enforcement actions, exceeding 2012’s total of 25.

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What is Your Board’s Investigation Protocol?

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

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).

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Latin America’s Top FCPA Stories of 2013

In the world of FCPA enforcement, 2013 was a big year. Some have pointed out, “After getting off to a slow start, with no official corporate FCPA settlements announced in the first quarter, 2013 witnessed two of the top 10 biggest settlements of all time.”