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advice5_Fotor

Doctor “No” Versus Doctor Practical

Better to keep your mouth shut and appear stupid than to open it and remove all doubt. — Mark Twain Years ago (seems like eons), I wrote a column lamenting lawyers and compliance professionals...

DPA_Fotor

Future of Corporate Monitors

No company wants a corporate monitor. If you ask any General Counsel, Chief Compliance Officer or Chief Executive Officer, they can list an infinite number of alternative punishments they would rather suffer than have...

audit4_Fotor

Third Party Audits: Biting the Bullet

The next compliance frontier in anti-corruption enforcement is third-party audits. We have spent the last few years fashioning third-party audit contractual provisions to define when and how such audits can be conducted. The issue...

facilitation_Fotor

Sanctions Enforcement – Facilitation Violations

As sanctions enforcement continues to mature, the permutations of risks become more complex. One area where companies have significant exposure is when they can be accused of “facilitation.” It is a unique risk for...