Guest Post from Tiffany Kemp, Devant Limited Here in the UK, there has been much excitement about the implementation of the new Bribery Act, which comes into force on the 1st July 2011. “Experts” have appeared from nowhere, training courses abound, and consultants around the world have woken up to the enticing smell of new revenue opportunities. As compliance officers worry about how to implement...
Guest Post from Tiffany Kemp, Devant Limited Here in the UK, there has been much excitement about the implementation of the new Bribery Act, which comes into force on the 1st July 2011. “Experts” have appeared from nowhere, training courses abound, and consultants around the world have woken up to the enticing smell of new revenue opportunities. As compliance officers worry about how to implement...
Corporate Board members face even more risks in today’s aggressive FCPA enforcement environment. They have adjusted to the new post-Sarbanes-Oxley environment. Today, they face the perils of FCPA enforcement. As the Justice Department and the SEC bear down on more and more companies, Board members have to be even more sensitive and careful when it comes to FCPA enforcement. If you read between the lines...
Corporate Board members face even more risks in today’s aggressive FCPA enforcement environment. They have adjusted to the new post-Sarbanes-Oxley environment. Today, they face the perils of FCPA enforcement. As the Justice Department and the SEC bear down on more and more companies, Board members have to be even more sensitive and careful when it comes to FCPA enforcement. If you read between the lines...
Richard Alderman The legal marketing hysteria surrounding the UK Bribery Act is entertaining and surreal. Article after article, pitch after pitch focuses on the new D-Day: July 1, the effective date for the UK Bribery Act. Lawyers and commentators are trying to scare global companies into acting quickly to design and implement new compliance policies, or face the wrath of prosecutorial zeal. These claims...
Richard Alderman The legal marketing hysteria surrounding the UK Bribery Act is entertaining and surreal. Article after article, pitch after pitch focuses on the new D-Day: July 1, the effective date for the UK Bribery Act. Lawyers and commentators are trying to scare global companies into acting quickly to design and implement new compliance policies, or face the wrath of prosecutorial zeal. These claims...
Richard Alderman The legal marketing hysteria surrounding the UK Bribery Act is entertaining and surreal. Article after article, pitch after pitch focuses on the new D-Day: July 1, the effective date for the UK Bribery Act. Lawyers and commentators are trying to scare global companies into acting quickly to design and implement new compliance policies, or face the wrath of prosecutorial zeal. These claims...
Richard Alderman The legal marketing hysteria surrounding the UK Bribery Act is entertaining and surreal. Article after article, pitch after pitch focuses on the new D-Day: July 1, the effective date for the UK Bribery Act. Lawyers and commentators are trying to scare global companies into acting quickly to design and implement new compliance policies, or face the wrath of prosecutorial zeal. These claims...
Richard Alderman The legal marketing hysteria surrounding the UK Bribery Act is entertaining and surreal. Article after article, pitch after pitch focuses on the new D-Day: July 1, the effective date for the UK Bribery Act. Lawyers and commentators are trying to scare global companies into acting quickly to design and implement new compliance policies, or face the wrath of prosecutorial zeal. These claims...
One area where compliance officers and practitioners need to focus is on the requisite intent for a criminal violation. For compliance officers facing difficult policy choices on FCPA compliance policies, the touchstone of such policies should be the employee’s intent — was it criminal, negligent or benign? It is one thing to have a policy which requires prior approval for any gift to a foreign...
