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Of Course the FCPA Pilot Program Would Continue

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Let’s say you’ve put together a great compliance program, with policies in place to reduce business risk and curb corruption. But how do you know your program is actually working? If you know your program still needs to address a specific risk, how do you make your case for additional resources?
The Justice Department’s FCPA Pilot Program turns one year old this month. Celebrate if you feel the urge, but news of its extended lease on life—which a Justice Department official announced in March—should surprise nobody. The Pilot Program fits exactly with the Trump Administration’s emerging message on policing against corporate misconduct. Yes, technically the Justice Department is extending ...
Some companies question whether or not they should invest in a full-fledged compliance program. While the return on investment isn’t always obvious, a strong program can help your company avoid fines and legal expenses. In the United States, the Department of Justice (DOJ) and the Securities Exchange Commission (SEC) sometimes decline to pursue charges due to a company having an effective ...
Saying that you have policies and training in place to prevent corruption is one thing, but do you have controls built into your processes? A control could be thought of as hitting the pause button and taking a moment to prevent an action from becoming a huge problem. 
When chief compliance officers take a top-down approach, they are often met with resistance -- it’s just part of human nature. This dynamic can be observed in politics and the workplace, families and relationships, and it’s an ongoing issue in compliance. Whether you’re putting together a new compliance program or trying to improve or update an existing system, you won’t get anywhere by trying to ...
Willie Stargell, the Hall of Fame Pittsburgh Pirate Outfielder, once said that hitting Steve Carlton, another Hall of Fame pitcher, was as difficult as eating soup with a fork. Now you don’t have to be a baseball enthusiast to get that analogy. This kind of reminds me of Due Diligence for purposes of anti-bribery and corruption: On the surface it does not seem like that daunting a task, but ...
Corruption risks take a variety of forms, from expensive gifts and entertainment to politically-connected suppliers and facilitation payments. While the same rules may apply to everyone in the company, they affect each role differently. For example, salespeople are likely to face different compliance challenges than those on the finance team, and require different training. But people tend to ...
ZTE Corp, a Chinese telecom company with annual revenue exceeding $15 billion, is rumored to be finalizing a guilty plea to pay hundreds of millions to the United States in conjunction with allegations of illegal sales to Iran.  Reuters first reported the pending plea today here.  Reuters’ source, who declined to speak on the record, suggested ZTE may be working with the Departments of Justice, ...
(Want to get articles like this one by email?  Here is the sign-up!)  Notwithstanding the importance of compliance programs to companies, there is no one-size-fits-all formula to design the perfect anti-corruption compliance program. This is where compliance risk assessments come into the picture; a risk assessment is a critical first step in developing an anti-corruption compliance ...
The year 2016 has set the record for FCPA enforcement; 27 companies paid about USD 2.48 billion to resolve FCPA cases. Indeed, prosecutors rely on large criminal fines for companies and jail time for executives to deter corruption offences. These direct costs, together with indirect damage to the company’s reputation and lost business opportunities, make compliance the more attractive alternative ...