It’s seems obvious to say that corporate leaders would prefer to steer clear of bribery and corruption violations, especially given all of the recent media attention surrounding enforcement of the FCPA and UK Bribery Act.
Thomas Fox discusses seven steps to consider when devising a strategic plan for your compliance program in conjunction with Stephen Martin’s thoughts for a 1-3-5-year strategic plan.
This article originally appeared on Professor Koehler’s FCPA Professor website (www.fcpaprofessor.com) and is reprinted with his permission. As noted in this prior article, the U.K. Ministry of Justice (“MoJ”) has a consultation process open concerning its proposal to adopt deferred prosecution agreements. Below is the text of my letter to the MoJ urging it to say no to DPAs in the Bribery Act context. You too can [...]
In the face of ever more aggressive enforcement of anti-corruption and wider anti-financial crime legislation, the management teams of even the most well-prepared multinational companies are asking themselves not “if,” but “when” they will have to take their organization through a regulatory investigation.
Thomas Fox tells a modern Fractured Fairy Tale about U.S. businesses that have to work under the FCPA in Africa.
The OECD recently released its Phase 3 Report on Implementing the OECD Anti-Bribery Convention in the United Kingdom. Mike Koehler provides a brief overview of certain issues in the report.
Most of the business news last week has been dominated by JPMorgan Chase & Co.’s (JPM) announced $2.3 billion trading loss. Early on there was focus on JPM’s trading operations in London, as the cause of this massive loss and even one trader, nicknamed the “London Whale,” has fueled the debate about banks taking such large positions, [...]
There has been rampant speculation that under the U.K. Bribery Act, corporations may well be prosecuted for providing corporate hospitality events before or during the Olympics. Thomas Fox relays the SFO’s response when TheBriberyAct.com guys posed the question.
Serving on an audit committee is one of the most challenging, prestigious and fulfilling roles a business professional can play. It provides the opportunity to give back by sharing knowledge gained and lessons learned firsthand. And yet, the job’s inherent responsibilities can result in a very serious case of sleep deprivation. The results of the [...]
Clifford Chance’s Wendy Wysong and Charles-Henri Boeringer take a look at the current state of private sector bribery in Asia Pacific.