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Refocusing Due Diligence on Cartel and TCOs (Part I of II)

Companies face a dual challenge — the pressing need to unravel their supply chains, and the immediate task of recalibrating due diligence systems to examine potential presence of cartel and transnational criminal...more

Episode 374 -- Justice Department Resumes FCPA Enforcement with New, Focused Guidance [Audio]

The Justice Department has returned to the FCPA enforcement arena -- in a significant development, DOJ announced the resumption of FCPA enforcement, with a new set of enforcement guidance principles. The new guidance is an...more

Episode 374 -- Justice Department Resumes FCPA Enforcement with New, Focused Guidance [Audio]

The Justice Department has returned to the FCPA enforcement arena -- in a significant development, DOJ announced the resumption of FCPA enforcement, with a new set of enforcement guidance principles. The new guidance is an...more

Justice Department Resumes FCPA Enforcement with New, Focused Guidance (Part I of II)

The Justice Department has returned to the FCPA enforcement arena — in a significant development, DOJ announced the resumption of FCPA enforcement, with a new set of enforcement guidance principles.  The new guidance is an...more

Global Anti-Corruption Efforts and DOJ’s FCPA Pause

The Justice Department’s six-month pause on FCPA enforcement has left a gap in the global anti-corruption fight.  The Justice Department played a critical role in coordinating international efforts and enforcement.  in the...more

The Brave New World — Due Diligence to Identify Cartels and TCOs

When assessing your third-party risks, it is important to start with one important division — a company’s supply chain and on the flip side, a company’s distribution chain.  Sourcing materials and supply chain links present a...more

Episode 358 - Ethics and Compliance Trends for 2025: Is Your Company Prepared? [Audio]

Is your company prepared for the compliance storm ahead? With tariffs shaking global trade, aggressive sanctions enforcement, and new risks from AI, businesses must rethink their strategies. Can your compliance program keep...more

Episode 357 -- Updating Your Risks Under the New Trump Administration [Audio]

Are You Ready for the Next Wave of Corporate Risk? Corporate risks are shifting, and every board, C-suite, and compliance team must take a fresh look at their risk landscape. While some risks like cybersecurity, data...more

Updating Your Risk Profile to Respond to the New Trump Administration

We live in a topsy-turvy world.  This is an exaggeration but sets up my points in this blog post. We are now seeing the shuffling of corporate risks and every board, C-Suite and legal, compliance and risk management team has...more

Episode 356 -- Trump Administration Hits Pause on FCPA Enforcement [Audio]

What happens when an entire era of anti-corruption enforcement is put on pause? Is this a strategic move to bolster American businesses or a dangerous rollback of corporate accountability? In an unprecedented move, the...more

Sifting Through the Rubble — What to Make of the Topsy-Turvey World of FCPA Enforcement?

The dust is settling and for all the drama surrounding the Trump Administration’s refocus on FCPA enforcement, the picture is becoming a little bit clearer.  When cooler heads prevail, it is much easier to pick through the...more

New FCPA Guidance — What to Expect (Part IV of V)

As we continue through the maze of Executive Orders and new Guidance, which is expected in 180 days, the questions surrounding FCPA enforcement are swirling.  In some respects, we have had a preview.  It is hard to know what...more

Taking Stock of the FCPA Fallout (Part III of V)

What an amazing turn of events? — Who would have predicted that the Trump Administration would take such a bold action in the name of advancing “American Competitiveness.” I admit I did not see this coming — the Trump...more

Trump Administration Hits Pause on FCPA Enforcement (Part II of V)

In an unprecedented action, the Trump Administration pushed the button and ended FCPA enforcement, at least for 180 days, until new guidance is issued by the Department of Justice.  The White House’s announcement seemed to...more

FCPA Predictions: Don’t Expect Much to Change

In 2017, when President Trump first took office, big changes were expected in FCPA enforcement.  Much of this reflected President Trump’s expressed misgivings on the substance of the FCPA.  He was not a big fan of the law and...more

OFAC Settles with Individual for $45,179 for Violations of the Global Magnitsky Act

OFAC means what it says — in more ways than one.  In a precedent setting case, OFAC brought its first enforcement action against an individual for violating the Global Magnitsky Sanctions Regulations....more

The Sanctions Year in Review: DOJ takes First Steps to Enforce “The New FCPA” While OFAC’s Enforcement Actions Decline

Enforcement and compliance prognosticators (like myself) continued to push DOJ’s promise to transform sanctions enforcement into the era of “the new FCPA.” While DOJ’s promise to bring about an aggressive corporate...more

FCPA 2024 Enforcement — Bribery Schemes and Compliance Reminders (Part II of III)

Criminals can be creative — that is a true statement but essentially FCPA criminals have to embrace a variety of well-established techniques to accomplish a straight-forward goal — steal money from the company to funnel...more

The FCPA Year in Review — More of the Same with Some Twists (Part I of III)

With the end of the Biden Administration, it is hard to identify a consistent theme relating to FCPA enforcement.  On the one hand, the Biden Administration talked a big game, elevating the anti-corruption fight as a national...more

AAR’s Bribery Schemes: Bribery in the Aviation Industry (Part II of II)

AAR, a provider of aviation products and services, engaged in two separate bribery schemes. State-owned entities and government agencies permeate the aviation industry. As a result, FCPA risks are embedded in direct...more

McKinsey Company's Bribery Scheme - A Familiar Pattern in South Africa (Part II of III)

The McKinsey FCPA case follows several other significant cases involving South Africa.  ABB and SAP resolved FCPA cases involving bribes in South Africa; on the SEC front, Gartner resolved a bribery case involving South...more

Episode 349 -- Review of the BIT Mining FCPA Settlement [Audio]

What happens when a Chief Executive Officer becomes the architect of a global bribery scheme? In this episode of Corruption, Crime, and Compliance, Michael Volkov delivers an in-depth analysis of the BIT Mining FCPA case —...more

Measuring Compliance Program Performance and Effectiveness

You often hear chief compliance officers speak about benchmarking. CCOs often reveal their competitive streaks when they collect information about other companies’ compliance programs. It can easily come off as a little...more

Episode 343 -- TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations [Audio]

How does a respected financial institution turn into a criminal operation? In this episode of Corruption, Crime, and Compliance, host Michael Volkov dives into the record-breaking $3 billion settlement between TD Bank and the...more

Episode 342 -- How to Conduct an Internal Compliance Site Visit and Review [Audio]

How can companies ensure that their compliance programs are robust enough to handle today’s complex ethical challenges? In this episode, Michael Volkov dives into the critical components of conducting an internal compliance...more

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