Tagged: Third-party risk management

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...

Keeping Track of Third Party Risks – Bribery and Sanctions

We have heard it over and over, again and again – third-parties pose significant risks of bribery for all global businesses.  Almost every FCPA enforcement action includes some form of third-party misconduct.  The current picture from the Stanford FCPA Resource confirms the story. A cottage industry of automated platforms, data analytics, due diligence and monitoring strategies have grown around third-party bribery risk.  Companies have designed...

Episode 200 — The Foster Wheeler FCPA Enforcement Action

The Justice Department and the Securities Exchange Commission are back in business.  The first corporate FCPA enforcement action in 2021 came after a six-month hiatus in 2021. The first case against a corporate entity in 2021 is an interesting one because it reflects a coordinated settlement not only between DOJ and the SEC but the U.K.’s Serious Fraud Office and Brazil’s Ministério Público Federal (MPF),...