Compliance Communications Blog

 

"Before You Can Educate, Get Their Attention"

 

6/30/15: In a post in the Communicating Compliance blog, Joel A. Rogers dares compliance officers to look away from the title when he advises the first step in FCPA compliance. He writes, “Stop training your employees in FCPA compliance!” From that cant-ignore headline, Joel goes on to offer straightforward...

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"Declination May Not Be the End"

 

6/16/15: Declinations are usually perceived as the end of an enforcement action but recent actions by US enforcement agencies show otherwise. According to a post by Richard Cassin on the FCPA Blog, the US Securities and Exchange Commission recently notified NET1 UEPS Technologies that it declined to recommend...

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"Using Best Practices for a Cross-Border Investigation"

6/16/15: Tom Fox starts out with Babe Ruth but he quickly moves on to an interview with Mara Senn, a partner at Arnold & Porter LLP, on the topic of best practices for conducting an effective cross-border investigation. Fox’ two-part series posted on his FCPA Compliance and Ethics Blog pinpoints 10 best practices...

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"FCPA Enforcement as US Foreign Policy"

 

6/16/15: In an essay on the CFO website, former federal and NYS prosecutor Daniel R. Alonso takes an unexpected look at recent US anti-corruption enforcement.  “Increasingly,” he writes, “the U.S. government is wielding the FCPA as a tool to change corrupt cultures in other countries. If the government...

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