Bribery Act

  • Doing Less with Less and the Unification of Germany

    … compliance program and your business model to see what are your highest risks. If you believe there are several, you can fprioritize them. This exercise will give you the basis to deliver your ever-scarcer compliance resources to your highest risk areas. While I do not believe the Department of Justice (DOJ) or Securities and Exchange Commission (SEC…

    USA Recht- 43 Leser -
  • Doing Business in India – Corruption Risks and Responses

    … Recently the US law firm of Foley and Lardner LLP and MZM Legal, Advocates & Legal Consultants in India jointly released a white paper, entitled “Anti-Bribery and Foreign Corrupt Practices Act Compliance Guide for U.S. Companies Doing Business in India”. For any compliance practitioner it is a welcome addition to country specific…

    USA Recht- 45 Leser -


  • Code of Conduct, Compliance Policies and Procedures-Part I

    … drafting your Code of Conduct and anti-corruption compliance policies and procedures and how to assess, review and revise them on a timely basis. The cornerstone of a US Foreign Corrupt Practice Act (FCPA) compliance program is its written protocols. This includes a Code of Conduct, policies and procedures. These requirements have long been memorialized…

    USA Recht- 71 Leser -
  • When to Bring in Investigative Counsel and Why

    … that don’t receive much media attention. A company deals with a problem quickly, and if there’s something to report to authorities, the company tends to be treated leniently for its forthrightness.” Amen. Filed under: Best Practices,Bribery Act,Chief Compliance Officer,compliance programs,Fair Process Doctrine,FCPA,Investigations,Jim McGrath,New York Times — tfoxlaw @ 12:01 am Tags: compliance, compliance programs, FCPA, Foreign Corrupt Practices Act, internal investigations, New York Times, NYT © Thomas R. Fox, 2014 …

    USA Recht- 85 Leser -
  • How Straight From The Lion’s Mouth Informs Your Hotline

    … The symbol of Venice is the Lion of St. Mark. The use of this symbol led to the maxim ‘straight from the lion’s mouth’. This adage came about because the Republic of Venice had its own hotline system where citizens could report misconduct. A citizen could write down his concern on paper and literally put the message into the mouth of statues…

    USA Recht- 21 Leser -
  • Farewell to Bum and Bud: Trends in FCPA Compliance and Enforcement

    … engage in corruption and bribery across the globe. Finally, do not forget the basics of any anti-bribery and anti-corruption compliance program remains the same, Document, Document, and Document. Filed under: Best Practices,Bribery Act,compliance programs,Corruption in China,Department of Justice,FCPA,SEC — tfoxlaw @ 1:01 am Tags: best practices, compliance, compliance programs, Department of Justice, DOJ, DPA, FCPA, FCPA Professor, internal investigations, SEC © Thomas R. Fox, 2013 …

    USA Recht- 32 Leser -
  • FCPA: The Bribery Act in 2012: a Year for Transition

    … and self-reporting. As noted by Barry Vitou and Richard Kovalevsky, QC, writing in thebriberyact.com, “The honeymoon is over.” They went on to say that “The revised guidance is a model of clarity. The new Director has previously made his position clear namely that the SFO is not there to provide guidance and those seeking it should liaise…

    USA Recht- 31 Leser -
  • FCPA: The Bribery Act in 2012: a Year for Transition

    … and self-reporting. As noted by Barry Vitou and Richard Kovalevsky, QC, writing in thebriberyact.com, “The honeymoon is over.” They went on to say that “The revised guidance is a model of clarity. The new Director has previously made his position clear namely that the SFO is not there to provide guidance and those seeking it should liaise…

    NIETZER & HÄUSLER- 38 Leser -
  • FCPA: Using History to Create or Rebuild a Compliance Culture

    … I have wondered how organizations such as Siemens, Alcatel-Lucent or any others that have faced a wide-ranging, global charge of systemic bribery and corruption might change their culture. Many others have written about the structural changes that such companies have made. For instance, the compliance monitor for Alcatel-Lucent, Laurent Cohen…

    USA Recht- 73 Leser -
  • The High Costs of Non-Compliance!

    …: Best Practices,Bribery Act,compliance programs,Department of Justice,FCPA,Mary Jones,Wal-Mart — tfoxlaw @ 1:01 am Tags: best practices, compliance, compliance programs, Department of Justice, DOJ, ethical leadership, ethics, FCPA, Mary Shaddock Jones © by Mary Shaddock Jones …

    USA Recht- 72 Leser -
  • Armistice Day: The Risks and Rewards of Foreign Joint Ventures

    …Ed. Note-we continue our series of guest posts from our colleague Mary Shaddock Jones, who today looks at Joint Ventures and has some pointers for avoiding pitfalls under the FCPA. In December 2010, RAE Systems Inc., a publicly-traded U.S. corporation headquartered in San Jose, Calif., has entered into an agreement with the Department of Justice…

    USA Recht- 7 Leser -


  • Election Day – Just Who is a Foreign Government Official?

    … of the importance of freedom of speech, and the concomitant duty that freedom imposes upon us all, to speak up for what we believe is right or wrong. Speaking of which, this leads me to today’s topic – the Haiti Telecom case. In 2009 the Department of Justice charged Juan Diaz with conspiracy to make corrupt payments to Haitian officials for the purpose…

    USA Recht- 15 Leser -
  • FCPA: The Five Essential Elements of a Corporate Compliance Program – Part II

    … compliance best practices now require companies to have additional standards and controls, including, for example, detailed due diligence protocols for screening third-party business partners for criminal backgrounds, financial stability and improper associations with government agencies. Ultimately, the purpose of establishing effective standards…

    USA Recht- 22 Leser -
  • FCPA: The Five Essential Elements of a Corporate Compliance Program-Part I

    … of a corporate compliance program. I hope that you can attend our FCPA event next week. For those of you who cannot attend in person, you can email me for the slide deck and other materials after the event. Filed under: Best Practices,Bribery Act,compliance programs,Ethical Leadership,FCPA,Federal Sentencing Guidelines,OECD,Risk Assessment,Stephen Martin,Tone at the Top — tfoxlaw @ 1:28 am Tags: best practices, Bribery Act, compliance, compliance programs, Department of Justice, DOJ, FCPA, Risk Assessment © by Thomas R. Fox, 2012 …

    USA Recht- 26 Leser -
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