gatekeepers Archives - Corruption, Crime & Compliance

16 Dec, 2021

The United States Strategy on Countering Corruption: Digging into the Anti-Corruption Initiatives (Part III of III)

The new United States Strategy on Countering Corruption includes several important statements of interest to legal and compliance professionals. Under the third of the five pillars, Holding Corrupt Actors Accountable, the U.S. Government specifically calls out the importance of private sector commitment to anti-corruption compliance programs “to improve the international business climate by encouraging the adoption and enforcement of anti-corruption compliance programs by U.S. and...

General

15 Dec, 2021

Biden Administration Announces New Anti-Corruption Strategy (Part I of III)

The Biden Administration announced a new, comprehensive anti-corruption program, the United States Strategy on Countering Corruption. The new anti-corruption policy is the follow on to the earlier announcement elevating the global anti-corruption battle to a national security concern. After that announcement, the Biden Administration conducted a 200-day inter-agency examination to develop a comprehensive government-wide anti-corruption initiative. The Biden Administration released the new United States Strategy...

General

3 Dec, 2020

Gatekeeper Misfires and Corporate Governance Failures

Here is another obvious point – internal controls are intended to ensure compliance with relevant policies and procedures. Internal controls are not just for show, or not just limited to financial reporting. A compliance program is a subset of a company’s internal controls. So, all this is well and good. But it appears that a number of companies have been getting into trouble because they...