Tagged: culture of ethics and compliance

Lessons Learned from the Honeywell FCPA Settlement (Part III of III)

The Honeywell FCPA settlement underscored a number of important issues – lessons learned for compliance professionals.  Every FCPA case carries important lessons learned, but some more than others.  The Honeywell case with its focus on the large project in Brazil, and the contractual dispute in Algeria both provide important pointers relating to third party risk management.  In addition to the third party issues, however, Honeywell...

The Glencore Settlement: Lessons Learned (Part V of V)

The Justice Department has resumed FCPA enforcement with a bang.  The new enforcement approach has been unveiled and the message for CCOs and corporate business leaders is clear — anti-corruption compliance should be a critical compliance priority.  Companies that fail to do so will be severely punished.  The new DOJ approach stands as one of the most important events elevating the importance of corporate compliance...