Category: General

Glencore Pleads Guilty and Resolves Foreign Bribery and Market Manipulation Charges — Pays Over $1.1 Billion (Part I of V)

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27 May, 2022

Glencore Pleads Guilty and Resolves Foreign Bribery and Market Manipulation Charges — Pays Over $1.1 Billion (Part I of V)

In a long-anticipated and major enforcement action, the Justice Department and the Commodities and Futures Trading Commission resolved a sprawling investigation with Glencore International A.G. and Glencore Ltd, a Swiss-based commodity trading and mining company. Glencore entered guilty pleas for FCPA violations and a commodity price manipulation scheme. Glencore paid over $1.1 billion to resolve these two major investigations. The resolution in the U.S. was...

General

26 May, 2022

Responding to Supply Chain Glitches and Increased Bribery Risks

The evolution in the global economy is raising challenges for anti-corruption compliance. In response to economic dislocations and disruptions stemming from the COVID-19 pandemic and Russian invasion of Ukraine, businesses encounter situations where supply chain delays and disruptions inevitably increases bribery demands and pressures. A perfect example of such a situation was the delay in export of essential goods from China to the United States...

General

25 May, 2022

Allianz Global Hit With $6 Billion Fine And Portfolio Manager Indicted in Connection with Million-Dollar Fraud Scheme

In a blockbuster settlement, DOJ unleashed its full power against Allianz Global and key portfolio managers responsible for a massive, long running fraud scheme involving a series of private investment funds managed by Allianz Global Investors U.S. (AGI). These funds eventually collapsed as a result of the economic hardships caused by the pandemic, resulting in investor losses of billions of dollars. Gregoire Tournant, Chief investment...

General

24 May, 2022

DOJ Criminal Division AAG Underscores Role of CCOs and Announces CCO Certification Requirements

In a homecoming speech, DOJ’s Assistant Attorney General Kenneth Polite gave a rousing speech to a room full of compliance professionals at the annual Compliance Week meeting in Washington, D.C. AAG Polite, who has served as a CCO himself, embraced the mission of compliance officers as a critical part of corporate governance systems. AAG Polite specifically recognized the importance of the compliance functions and the...

General

20 May, 2022

Third-Party Risk Mitigation and Monitoring (Part V of V)

It is easy to be overwhelmed by the overall risk profile of your third-party population. The best way to tackle the problem is by defining specific problems and risks and then analyzing a subset of third parties as to this specific problem or risk. On the operational side, the business can guide this inquiry, especially procurement professionals who should be familiar with the direct and...

General

19 May, 2022

Identify and Understand Your Third-Party Population (Part IV of V)

It is an initially daunting task — identify all of your third-party partners with whom your company conducts business. For large global companies, this is no easy issue. Some companies do not have readily available a list nor an understanding of the size and scope of their third-party population. That can be an initial hurdle unto itself. The first step usually involves some kind of...

General

18 May, 2022

The Upside of Managing Third-Party Risks: Advancing Your Culture (Part III of V)

While I have devoted the first two postings to outlining all the downside risks of third-party management and threats to overall organization resiliency and operations, it is important to consider the positive upside of managing your third party population. After all, a large number of third parties represent your organization, such as agents, distributors, and resellers, in the marketplace and frequently interact with company customers. ...

General

17 May, 2022

Adjusting Your Perspective — Identifying Your Real Third-Party Risks (Part II of V)

Compliance professionals are always looking for ways to collaborate and support internal business partners. Through the years, compliance professionals have devoted significant energy to building partnerships with the business. Compliance has and should continue to build a strong relationship with business as a meaningful value-add. This process has been accelerated by the Covid and Ukraine crises and increasing cyber risks stemming from data breaches and...

General

16 May, 2022

Renewing Your Third-Party Risk Management Vows — A Real World Perspective (Part I of V)

When you get on the mailing lists for legal and compliance products, seminars, conferences and general palabra, I usually become transfixed. Millions of marketing and promotion dollars are being spent in an attempt to distinguish or highlight the subject of third-party risk, position a product or highlight the expertise of a speaker. Sometimes I take the time to read some of the emails — to...

General

12 May, 2022

United States and EU Expand Russian Sanctions and Export Controls

In its continuing ratcheting of sanctions against Russia, the United States and the European Union have announced new sanctions and export controls to target additional industries and government officials. In a new front, the US and EU included a ban on accounting and business consulting services. The new US restrictions extend to broad export controls and sanctions focused on Russian banking executives, a weapons manufacturer...

Category: General

Glencore Pleads Guilty and Resolves Foreign Bribery and Market Manipulation Charges — Pays Over $1.1 Billion (Part I of V)

Responding to Supply Chain Glitches and Increased Bribery Risks

Allianz Global Hit With $6 Billion Fine And Portfolio Manager Indicted in Connection with Million-Dollar Fraud Scheme

DOJ Criminal Division AAG Underscores Role of CCOs and Announces CCO Certification Requirements

Third-Party Risk Mitigation and Monitoring (Part V of V)

Identify and Understand Your Third-Party Population (Part IV of V)

The Upside of Managing Third-Party Risks: Advancing Your Culture (Part III of V)

Adjusting Your Perspective — Identifying Your Real Third-Party Risks (Part II of V)

Renewing Your Third-Party Risk Management Vows — A Real World Perspective (Part I of V)

United States and EU Expand Russian Sanctions and Export Controls

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