Compliance Programs


    … courses”. Certainly recognizing that inane training is simply that – inane training, Anderson missed the larger picture of what constitutes a best practices compliance program. Training is one part of a larger component of how companies manage their compliance with laws, regulations and, most importantly, the ultimate barometer of their value…

    Wolf M. Nietzer/ USA Recht- 49 Leser -

  • Compliance Training – Part II: Risk Ranking and Design

    … should incorporate into your Foreign Corrupt Practices Act (FCPA) compliance program. The communication of your anti-corruption compliance program is something that must be done on a regular basis to help ensure its effectiveness. The FCPA Guidance explains, “Compliance policies cannot work unless effectively communicated throughout a company…

    Wolf M. Nietzer/ USA Recht- 79 Leser -
  • Senn on 10 Best Practices in a Cross-Border Investigation – Part I

    … Today we celebrate a closure for it was on this day in 1935 that probably the best-known baseball player in the history of the game, George Herman ‘Babe’ Ruth, retired. While many of his records were broken with the march of history, his career slugging percentage of .690 remains the highest in Major League history. He was an oversized character…

    USA Recht- 65 Leser -
  • Managing Your Third Parties in a FCPA Compliance Program

    … The building blocks of any Foreign Corrupt Practices Act (FCPA) anti-corruption compliance program lay the foundations for a best practices compliance program.For instance in the lifecycle management of third parties, most compliance practitioners understand the need for a business justification, questionnaire, due diligence, evaluation…

    USA Recht- 34 Leser -
  • Doing Less with Less and the Unification of Germany

    … downturn is on everyone’s mind and a subject of much conversation. Last week I wrote a post about the depression of oil and gas prices in the energy space and some of the increased Foreign Corrupt Practices Act (FCPA) or other anti-corruption risks that might well arise from this economic downturn. Over the next couple of days, I want to explore how…

    USA Recht- 43 Leser -
  • Revisiting The Raven and Visiting Foreign Subsidiaries

    … On January 19 we celebrated the birth of one of America’s most iconic authors, Edgar Allen Poe, who was born on this day in Boston, Massachusetts. Anyone who reads or watches a mystery show on television owes a debt to Poe for inventing the genre. Poe flunked out of West Point but later became an editor at the Southern Literary Messenger…

    USA Recht- 36 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 -
  • Due Diligence Going Forward in China

    … received a two year jail term and was ordered to pay a fine of approximately $23,000 but will be allowed to remain in the country after her sentence is completed. In a New York Times (NYT) article, entitled “In China, British Investigator Hired by Glaxo, and Wife, Sentenced to Prison”, David Barboza reported that the couple “acknowledged that from 2009…

    USA Recht- 70 Leser -
  • Code of Conduct, Compliance Policies and Procedures-Part I

    … Prosecution Agreement (DPA) and Non-Prosecution Agreement (NPA). These requirements were incorporated into the 2012 FCPA Guidance. The FSG assumes that every effective compliance and ethics program begins with a written standard of conduct; i.e. a Code of Conduct. What should be in this “written standard of conduct? The starting point, as per…

    USA Recht- 71 Leser -

  • The HP FCPA Settlement

    … involved, evidencing an entire breakdown in company internal controls and a complete lack of a culture of compliance. Yet the settlement documents make great pains to emphasize that few employees were actually involved in the nefarious conduct. How bad was the conduct? Think right up there with BizJet because we had bags of cash delivered to a Polish…

    USA Recht- 60 Leser -
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