Category: Uncategorized

FCPA Fugitives

The FCPA has broad extraterritorial reach. Everyone knows that and understands how foreign conduct can be prosecuted in the United States courts. FCPA violators, however, are learning about the long-arm of the law and...

Compliance Fatigue: You’re Kidding, Right?

You have to admire some people for their chutzpah. In a recent Global Fraud Survey conducted by Ernst & Young (available Here), survey results suggested that anti-corruption compliance may be “running out of steam.”...

CCO Reporting to Board: Five Best Practices

Chief Compliance Officers need the support of their Board of Directors. The relationship between the CCO and the head of the Audit/Compliance Committee sends an important message to senior management and the entire company...

FCPA Mid-Year Assessments

The Internet is littered with FCPA Mid-Year Assessments and reports on enforcement activity and so-called trends and developments. Talk about making mountains out of molehills. Some of the reports are excellent; others are rehashes...