All FCPA articles – Page 19
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Risk assessments
A detailed guide from the Man From FCPA on how to perform an effective risk assessment.
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Written protocols for compliance
Tom Fox explores written protocols, the foundation upon which an effective compliance program is built.
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Those pesky hot mikes and insider-trading laws
Inside is a look at the actions of the Batista brothers, leaders of corrupt firm JBS, which highlights a part of any corruption resolution across the globe: If you hold back information from the government, you will be subject to prosecution for those crimes as well.
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Structure of the CCO position
The Man From FCPA explores the three prisms by which the structure of the Chief Compliance Officer position can be evaluated: access, resources, and opportunities.
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Tone in an organization
Tom Fox explores the many levels of corporations and how they interact to create tone at the top, middle, and bottom.
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Uber and “Hell”
The hits keep coming to beleaguered transportation firm Uber; reports have surfaced that an internal company program called “Hell” utilized software that allowed it to illegally interfere with Lyft, an Uber competitor.
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Going weird in international bribery and corruption
As Hunter S. Thompson once said, “When the going gets weird, the weird turn pro.” Such is the case of BSG Resources after accusations surfaced that the company had paid bribes to obtain a huge mining concession in Guinea—charges it vehemently denies.
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New scandals; new lexicon for unethical conduct
In the FCPA world, the most dreaded question during an enforcement action is “where else?”—as in, where else are you engaging in bribery and corruption? After Wells Fargo, the lexicon may well expand to “what else?”—as in what other conduct is your company engaging in that is unethical?
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For leniency, confess all crimes
The JBS meat-packing scandal is a perfect example of why companies must provide every single shred of evidence of criminal conduct, or a plea agreement might not be worth much.
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What are the effects of C-Suite involvement in bribery and corruption?
A look at the corruption cases of Samsung and Panalpina and the outcome from when C-Suite becomes involved in corporate bribery and corruption schemes.
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Preparing for compliance
One lsson learned from Hurricane Harvey applies to today’s compliance professional: You must do more than prepare for a compliance emergency by preparing beforehand, but you must also practice that preparedness.
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Vantage Drilling: Justice Department ends FCPA probe
Vantage Drilling Company, an offshore drilling contractor, announced this week that it will not be facing an enforcement action from the Department of Justice regarding a previously disclosed investigation into potential violations of the Foreign Corrupt Practices Act.
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Archrock names general counsel amid FCPA probe
Archrock Partners has appointed Stephanie Hildebrandt as senior vice president and general counsel, effective Aug. 7. Hildebrandt's appointment comes amid an ongoing Foreign Corrupt Practices Act investigation in connection with certain previously disclosed errors and possible irregularities at one of its former international operations.
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How Hui Chen prompted an evolution in compliance at the DoJ
Hui Chen’s time as compliance counsel at the DoJ’s Fraud Section was short and eventful and did a lot to move the needle on how the DoJ views corporate compliance programs.
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Halliburton settles FCPA case for $29.2M
Oil field services giant Halliburton today reached a $29.2 million settlement with the SEC over charges that it violated the books and records and internal accounting controls provisions of the Foreign Corrupt Practices Act concerning payments tied to Angola.
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Article
FCPA Pilot Program leads to two 2017 declinations
The FCPA Pilot Program declinations we have seen so far in 2017 both make substantial additions to the precedent for how to avoid prosecution under the FCPA.
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Distilling lessons from the FCPA Pilot Program
A year after the DoJ launched its FCPA pilot program, companies are gaining much-valued insight on how to self-disclose and cooperate with the Criminal Division’s Fraud Section.
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New leadership, similar enforcement agenda
Amid plenty of public turmoil in the Trump administration’s early days, the enforcement agendas of both the DoJ and the SEC remain fundamentally unchanged.
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FCPA enforcement-giving confidence to financial markets
Judge Stanley Sporkin’s foresight in enacting the Foreign Corrupt Practices Act in the correct manner is a big reason behind why there is a large amount of confidence in U.S. companies.
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Will Odebrecht survive?
A look at how Odebrecht is trying to salvage itself from the ruins of its corrupt run as one of the leading construction companies in the Americas.