Tagged: Third-Party Risks

Ethics and Compliance Trends and Predictions

I always enjoy pulling out the crystal ball and looking forward with due consideration of last year’s trends.  It is a perspective that gives us all the opportunity  to identify important trends and to set an agenda for the next year – 2023. The compliance profession continues to grow in overall importance in the corporate governance landscape. Corporate leaders that fail to appreciate this face...

2022: The FCPA Year in Review

The Justice Department and the Securities and Exchange Commission bounced back in 2022 to restore their records for aggressive FCPA enforcement.  At the same time, DOJ announced significant new compliance program expectations, and appeared ready to press forward with a number of FCPA resolutions. The Numbers For the year, DOJ totaled five corporate resolutions, two separate declinations under its Corporate Enforcement Policy, and approximately 24...

Episode 222 — Managing Third-Party Sanctions Risks

Economic sanctions enforcement is a fast-rising risk for global companies. For many years, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) focused primarily on financial institutions. Over the last ten years, OFAC has stretched its enforcement eyes towards software, manufacturing, telecommunications and technology companies. With this growth in sanctions enforcement, OFAC has embraced an aggressive view of third-party risks. Like the FCPA, under OFAC’s regime, third parties...

Foster Wheeler FCPA Action: Dancing with the Devil – Risky Third Parties (Part II of III)

FCPA settlement actions often underscore specific compliance risks for legal and compliance professionals. If there ever was a case where third-party risks were bungled, and even intentionally embraced, the Foster Wheeler case provides  an important reminder for any organization focusing on third-party risk management.  The Foster Wheeler FCPA resolution could not be timed any better – with the expected increase in FCPA enforcement activity, DOJ...