Tagged: FCPA

21 Oct, 2018

NAVEX Global Releases 2018 Third-Party Risk Benchmark Report

NAVEX Global has issued its Third-PartyBenchmark Report. (HERE). The NAVEX Global Report contains important insights and data concerning ethics and compliance programs and third-party risk management strategies. I was pleased to assist NAVEX Global in preparing the 2018 Benchmark Report. Knowing how to appropriately define, screen and monitor your third parties is essential to minimizing risk. New industry benchmarks, along with the expert guidance provided in...

General

8 Oct, 2018

CEO Falls to SEC FCPA Settlement

Companies have definitely matured in the development and implementation of their ethics and compliance programs. Whether the pace has been rapid enough or is too slow, that is a debatable issue. A good litmus test for a mature ethics and compliance program is whether the company assesses and mitigates its C-Suite risks. Over and over again, companies fall under government scrutiny because of misconduct in...

General

6 Sep, 2018

Legg Mason Pays $34 Million to Resolve SEC’s Libyan FCPA Investigation

Legg Mason can finally close its books on the Gaddafi-era, Libyan bribery scandal. In June 2018, Legg Mason entered into a non-prosecution agreement with the Justice Department and agreed to pay $32 million for its role in the bribery scheme. Société Générale entered into a deferred prosecution agreement and paid $585 million for FCPA violations. Société Générale and Legg Mason admitted to paying over $90...

General

30 Aug, 2018

DOJ Issues Declination and Disgorgement Under FCPA Corporate Enforcement Policy

In a recently released letter (here), the Justice Department issued a declination to the Insurance Corporation of Barbados Limited (ICBL) for violations of the FCPA under the FCPA Corporate Enforcement Policy. DOJ required ICBL to pay approximately $93,000 in disgorgement. ICBL paid approximately $36,000 in bribes to Donville Innis, a Barbadian government official, in exchange for government contracts worth approximately $686,000 and $93,000 in profits....

Events

16 Aug, 2018

Webinar: FCPA Risks and Mergers and Acquisitions

Webinar: FCPA Risks and Mergers and Acquisitions September 5, 2018, 12 Noon EST Sign Up HERE Companies confront significant anti-corruption risks when acquiring other businesses. Successor companies have to conduct pre-closing due diligence and manage anti-corruption risks in the integration process. The Justice Department and the SEC have aggressively enforced the FCPA and are now encouraging companies to voluntarily disclose FCPA misconduct and cooperate. Join...

General

11 Jun, 2018

Justice Department Settles Gaddafi-Libya FCPA Cases with Société Générale and Legg Mason (Part I of III)

In a one-two punch of FCPA enforcement actions, the Justice Department announced two related FCPA settlements involving Société Générale and Legg Mason for Gaddafi-era bribery payments to Libyan officials. In the first settlement announced, Société Générale agreed to pay a total of $860 million in criminal penalties, $585 million for FCPA violations and $275 million in a separate investigation for manipulation of London InterBank Offered...

General

9 Nov, 2017

MyCompliance Office Webinar: Taking a Fresh Look at Gifts, Entertainment, & Hospitality Programs

Gifts, meals, entertainment, travel, and hospitality expenses (GMETH) are high-risk for bribery but have not received the same attention lately as third party risk management. The advancing capabilities of software solutions in this area make now the time to take a fresh look at how to leverage technology to strengthen your program. Join me and MyComplianceOffice for a free webinar to review: Best Practices to...

General

17 May, 2017

Effective Compliance and the Importance of Accounts Payable Function

As the compliance function has matured, Chief Compliance Officers have built important relationships with related functions that are critical to the compliance function. Over the last few years, we have seen the Justice Department and the SEC focus on company invoice to payment functions as a key area of concern when assessing the effectiveness of a compliance program. Last week, I had the honor of...

General

12 Mar, 2017

FCPA Pilot Program Motors On

No one was really surprised when Kenneth Blanco, Acting Assistant Attorney General for the Criminal Division, US Department of Justice, announced last week that DOJ was planning to continue the FCPA Pilot Program past April 5, 2017, the scheduled expiration date. Blanco stated in a speech given at the annual White Collar Crime Conference: Before I conclude, I would be remiss if I did not...

General

31 Jan, 2017

C-Suite Misconduct Results in Sociedad Quimica Y Minera FCPA Resolution with DOJ and SEC

In an unusual FCPA enforcement action, the Justice Department and the SEC resolved FCPA violations against Sociedad Quimica y Minera, a Chilean chemical and mining company, for a total of $30.5 million, for paying approximately $15 million in bribes to Chilean officials. SQM agreed to a deferred prosecution agreement (DPA) with DOJ and to assignment of a two-year independent compliance monitor. The odd aspect of...