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Watch Out Justice Department: Lessons Learned from the Past

Watch Out Justice Department: Lessons Learned from the Past

The Department of Justice is proud of its record on FCPA enforcement. They take credit whenever and wherever they can. They trumpet every settlement. They proudly proclaim that over half of last year’s criminal fines were collected for FCPA violations. They are entitled to claim success. It is hard to argue against prosecutions of private companies and individuals who engage in foreign bribery. Such conduct...

Watch Out Justice Department: Lessons Learned from the Past

Watch Out Justice Department: Lessons Learned from the Past

The Department of Justice is proud of its record on FCPA enforcement. They take credit whenever and wherever they can. They trumpet every settlement. They proudly proclaim that over half of last year’s criminal fines were collected for FCPA violations. They are entitled to claim success. It is hard to argue against prosecutions of private companies and individuals who engage in foreign bribery. Such conduct...

Watch Out Justice Department: Lessons Learned from the Past

Watch Out Justice Department: Lessons Learned from the Past

The Department of Justice is proud of its record on FCPA enforcement. They take credit whenever and wherever they can. They trumpet every settlement. They proudly proclaim that over half of last year’s criminal fines were collected for FCPA violations. They are entitled to claim success. It is hard to argue against prosecutions of private companies and individuals who engage in foreign bribery. Such conduct...

Watch Out Justice Department: Lessons Learned from the Past

Watch Out Justice Department: Lessons Learned from the Past

The Department of Justice is proud of its record on FCPA enforcement. They take credit whenever and wherever they can. They trumpet every settlement. They proudly proclaim that over half of last year’s criminal fines were collected for FCPA violations. They are entitled to claim success. It is hard to argue against prosecutions of private companies and individuals who engage in foreign bribery. Such conduct...

Taking a Risk: Anti-Corruption Compliance in the Merger and Acquisition World

Taking a Risk: Anti-Corruption Compliance in the Merger and Acquisition World

As the economy improves and merger activity increases, it is important to remember the risks of FCPA liability when acquiring a company or entering into a joint venture.  Simply put, you don’t want to acquire an FCPA violation.  Companies will sometimes rush to close a deal without conducting any due diligence — that is a recipe for disaster.  On the other hand, companies alert to...

Taking a Risk: Anti-Corruption Compliance in the Merger and Acquisition World

Taking a Risk: Anti-Corruption Compliance in the Merger and Acquisition World

As the economy improves and merger activity increases, it is important to remember the risks of FCPA liability when acquiring a company or entering into a joint venture.  Simply put, you don’t want to acquire an FCPA violation.  Companies will sometimes rush to close a deal without conducting any due diligence — that is a recipe for disaster.  On the other hand, companies alert to...

Anti-Corruption Compliance for Medium and Small Companies

Anti-Corruption Compliance for Medium and Small Companies

“People are doing the best that they can from their own level of consciousness.”  — Deepak Chopra If you travel on the anti-corruption seminar circuit (which is far more enjoyable than the proverbial “rubber chicken” circuit), you will hear from some of the most accomplished compliance professionals working at Fortune 50 companies. They are proud, and should be, about the compliance programs they oversee and...

Anti-Corruption Compliance for Medium and Small Companies

Anti-Corruption Compliance for Medium and Small Companies

“People are doing the best that they can from their own level of consciousness.”  — Deepak Chopra If you travel on the anti-corruption seminar circuit (which is far more enjoyable than the proverbial “rubber chicken” circuit), you will hear from some of the most accomplished compliance professionals working at Fortune 50 companies. They are proud, and should be, about the compliance programs they oversee and...

Anti-Corruption Compliance for Medium and Small Companies

Anti-Corruption Compliance for Medium and Small Companies

“People are doing the best that they can from their own level of consciousness.”  — Deepak Chopra If you travel on the anti-corruption seminar circuit (which is far more enjoyable than the proverbial “rubber chicken” circuit), you will hear from some of the most accomplished compliance professionals working at Fortune 50 companies. They are proud, and should be, about the compliance programs they oversee and...

Conflict Minerals Reporting Requirement

Conflict Minerals Reporting Requirement

The Dodd-Frank Wall Street Reform & Consumer Protection Act amended the Securities Exchange Act of 1934 by including a new provision requiring companies filing with the US Securities and Exchange Commission (SEC) to disclose whether their products use conflict minerals. The Act defines such conflict minerals as “columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives” and other minerals determined by the US Secretary of State...