Tagged: FCPA compliance

FCPA Compliance: Automation and Mitigating Gifts, Meals, Entertainment and Travel Expenditures Risks (Part III of V)

The laundry list of companies that have been prosecuted for FCPA violations surrounding gifts, meals, entertainment and travel expenditures is lengthy. Consider just two examples: In SEC v. Diageo (2011) (copy Here), Diageo agreed to a $16 million settlement for a variety of illegal bribe payments and GMET expenses, including $64,184 spent on rice cakes and other gifts for the South Korean military over a four-year...

FCPA Compliance: When a Foreign Official is a Third-Party (Part II of V)

Compliance officers are trained to spot risks.  They have an eagle eye and keen sensitivity.  In some cases they have to overcome inaccurate designations – my favorite is a “PEP,” a politically exposed person.  I sometimes hear the compliance equivalent of an “Oh, no, we can’t do business with him or her – he or she is a PEP.”  Of course, we all know that...

FCPA Compliance: The Importance of Relativity to Risk Ranking (Part I of V)

Any fool can know.  The point is to understand. – Albert Einstein Two things are infinite: the universe and human stupidity; and I’m not sure about the universe. – Albert Einstein This week I am posting a five-part series on FCPA compliance issues.  While there have been many advances in the anti-corruption ethics and compliance field, there is still more work to do to advance...

Episode 23 — Tom Fox and 2017 FCPA Year in Review

Tom Fox rejoins Corruption, Crime & Compliance for a 2017 FCPA Review.  Tom discusses important trends and events from 2017 in FCPA enforcement and compliance. Tom is the thought-leader on FCPA and compliance issues.  He maintains the popular blog, FCPA Compliance & Ethics, the Podcast Network and is a prolific author of numerous books, articles, and e-books.

Webinar: 2016 FCPA Enforcement and Compliance Year in Review — January 10, 2017 12 Noon EST

2016 FCPE Enforcement and Compliance Year in Review January 10, 2017 12 Noon EST Sign Up HERE The Justice Department and the SEC returned a big year in 2016 FCPA enforcement.  In April 2016, DOJ adopted its FCPA Pilot Program to encourage companies to self-disclose FCPA violations and cooperate with government investigations. Despite a slowdown in 2015 and early 2016, DOJ and the SEC brought...

DOJ’s New FCPA Enforcement Plan and Guidance (Part I of II)

The Justice Department finally released its long-awaited new FCPA enforcement plan. It took DOJ a little while to come up with this and in the end, like most initiatives, there is a mixed bag for global companies, FCPA practitioners, DOJ prosecutors and law enforcement. Today’s posting analyzes the initiative on prosecution issues, and tomorrow’s post will review the compliance component of the new guidance. DOJ’s...

Webinar: Compliance Program Pointers from Recent FCPA Enforcement Actions

Webinar: March 9, 2016, 12 Noon EST Sign Up Here FCPA enforcement actions provide important compliance tips and reminders for anti-corruption compliance programs. In this webinar, we will review FCPA enforcement actions for the last few years and present a number of important compliance program tips and reminders. Join Michael Volkov, CEO of The Volkov Law Group, for a discussion of FCPA enforcement actions and...