Menu12/16/14: What do we know about compliance – and non-compliance – and what do we think we know? The two aren’t necessarily the same according to a post by Bill Waite on the FCPA Blog. Citing a recent OECD analysis of 427 enforcement actions by nations that had signed the 1999 Anti-Bribery Convention shows that we may be operating under...
Compliance Communications Blog
Dec 16, 2014 •
12/16/14: What do we know about compliance – and non-compliance – and what do we think we know? The two aren’t necessarily the same according to a post by Bill Waite on the FCPA Blog. Citing a recent OECD analysis of 427 enforcement actions by nations that had signed the 1999 Anti-Bribery Convention shows that we may be operating under...
Dec 02, 2014 •
12/2/2014: An article by Elizabeth Gasiorowski Denis on the ISO website gives a current look at the status of corruption and the global fight against it. Toward the end of the article, she writes about the work underway on ISO 37001, which will “… take into account internationally recognized good anti-bribery practice.” The anticipated standard will...
Dec 02, 2014 •
12/2/14: For folks who missed the Pinsent Masons regulatory conference in London this fall, Richard Cassin gives an overview on his FCPA blog of David Green’s comments (the chief of the UK Serious Fraud Office). Green admitted that fraud was up – an all-too-familiar reality for compliance professionals – but so is enforcement by the UK’s Serious...
Sep 15, 2014 •
9/15/14: Most global companies grew up under the shadow of anti-corruption laws that criminalized the “giving side” of bribery. Bribes by employees or third parties to foreign government officials have been the focus of investigations, prosecutions and settlements in the millions or even billions of dollars. But, for every individual paying a bribe, there is...
Aug 01, 2014 •
8/1/14: Facilitation payments continue to bedevil compliance officers, and for good reason. Tom Fox frames a post about facilitation payments by recognizing that they represent one of the most confusing elements of the FCPA. But, he notes, “Facilitation payments are small bribes but make no mistake about it, they are bribes.” So, how...
