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).
I cannot think of any criminal enforcement actions against a corporation involving the Foreign Corrupt Practices Act (FCPA) where there was a lone wolf employee engaging in bribery and corruption on his or her own.
Brazil’s Clean Company Act Continues the Trend of Increased Risk Exposure For Companies Operating in BRIC Countries
In recent years, a number of BRIC countries – in particular Brazil, Russia and China – have committed to developing anti-corruption legal …
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, [...]