9/15/15: If you commit a crime once, is it inevitable that you’ll continue with the same behavior? In the world of public procurement in the European Union, the answer has been “yes” and the solution has been to ban a company guilty of bribery and corruption from participation in any public contract...
9/15/15: A recent report by KPMG gets straight to the point, even in its title, “Anti-Bribery and Corruption: Rising to the Challenge in the Age of Globalization.” Central to dealing with those challenges is managing the risks inherent in the use of third parties. The KPMG report is based on its global...
9/15/15: That’s the subject line in a recent memo from DOJ to federal prosecutors. The memo spells out a new policy for aggressively investigating and prosecuting individuals involved in corporate crimes. In a notable shift from DOJ’s traditional focus on prosecuting corporations, the memo sets...
9/1/15: The US Securities and Exchange Commission recently settled charges with Citigroup Global Markets saying the company failed to adopt and apply procedures that would prevent and detect transactions signaling the potential misuse of material, nonpublic information. The company also failed to adopt...
9/1/15: The UK’s Bribery Act was introduced as a robust counterpart to the US’ Foreign Corrupt Practices Act in fighting global corruption. In fact, the Bribery Act included several provisions that went beyond the FCPA. Since its enactment, the UK law has not been enforced as rigorously as anticipated. In response, the...
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