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Corruption Bribery Corporate Culture

Secretariat

Integrity and Accountability: Anti-Corruption Enforcement in Saudi Arabia

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As Saudi Arabia emerges as a global investment destination, it is essential for foreign investors, financial institutions, and legal and compliance professionals to understand the Kingdom’s anti-corruption initiatives,...more

Thomas Fox - Compliance Evangelist

Deere FCPA Enforcement Action: Lessons on Pre-Acquisition Due Diligence in M&A

We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 3 – The Comeback

Last week, Albemarle Corporation (Albemarle), agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more

The Volkov Law Group

Lessons Learned from Ericsson’s DPA Breach: An Internal Investigation Nightmare (Part III of III)

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This is not your typical FCPA enforcement action Lessons Learned column.  Instead, Ericsson’s breach of its DPA presents a laundry list of internal investigation errors – as a practitioner in this area, this is the nightmare...more

The Volkov Law Group

Glencore’s Bribery Schemes (Part III of V)

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The broad and pervasive scope of Glencore’s bribery conduct is obvious.  The scope of its misconduct reflects Glencore’s fatal culture and commitment to profits at any and all cost.  Glencore’s board and senior executive team...more

NAVEX

An Introduction to Anti-Bribery and Corruption

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What is Bribery and Corruption? A major key to running an ethical and compliant company, is to ensure that bribery and corruption is properly managed in all its forms. In doing so, companies can strengthen their ESG...more

Jenner & Block

Anti-Corruption Enforcement - 2021 Year in Review

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Due to the impact of the COVID-19 pandemic, and the change in presidential administrations in the United States in January 2021, US enforcement of the Foreign Corrupt Practices Act (FCPA) declined in 2021. However, we...more

Health Care Compliance Association (HCCA)

Dr. Jan Spafke and Jad Mhanna on Compliance in Non-Western Cultures

At the 2022 SCCE European Compliance & Ethics Institute Dr. Jan Sprafke, Head of Compliance, Europe and Latin America and Jad Mhanna, Regional Compliance Officer at Ericsson will be leading a session entitled Cultural Divide...more

American Conference Institute (ACI)

[Event] Anti-Corruption London - November 2nd - 3rd, London, United Kingdom

C5's 15th International Conference on Anti-Corruption London will take place November 2 – 3, 2021 in Millennium Hotel London Knightsbridge, London. Join your peers for the IN-PERSON reunion of the legal and compliance...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - August 9th - 12th, New Orleans, LA

Our Basic Academies are ideal for professionals with some compliance knowledge and experience who are ready to support, enhance and manage a comprehensive compliance program. They are taught by compliance professionals,...more

The Volkov Law Group

Deutsche Bank FCPA and Fraud “Spoofing” Settlement: A Review of Deutsche Bank Conduct (Part II of II)

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Deutsche Bank’s ethics and compliance function faces numerous challenges.  Deutsche Bank has a storied record of scandals, government enforcement actions and failures to abide by prior deferred prosecution agreements (DPAs)....more

The Volkov Law Group

Airbus Systemic Bribery and Export Violations: Understanding How a Company’s Compliance Program and Culture Failed (Part IV of IV)

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When reviewing a major enforcement case, I always ask two basic questions: What was the role of Board and senior management in the failure, and how did they fail to exercise proper oversight and ensure compliance?...more

WilmerHale

$1 Billion Ericsson Resolution, Three Jury Verdicts Cap Off Busy Fourth Quarter for US FCPA Enforcement

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On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...more

Thomas Fox - Compliance Evangelist

Preventing White Collar Crime

I conclude my short exploration of the recent set of articles in the Harvard Business Review (HBR) White Collar crime special section. Today, I want to look at an article by Mary Jo white, entitled “What I’ve Learned About...more

The Volkov Law Group

Board Members Should Take Note — Delaware Supreme Court Issues Important Decision on Caremark Compliance Standard

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I have long predicted that corporate board members are in for a rude awakening. Corporate boards have to improve their ability and knowledge surrounding supervision and monitoring of a company’s ethics and compliance...more

Thomas Fox - Compliance Evangelist

A Celebration of Compliance – General Motors 2018 Sustainability Report

The General Motors (GM) 2018 Sustainability Report is out. It reports on GM’s progress toward an era of safer, better and more sustainable personal mobility by transforming how General Motors approaches every aspect of its...more

Mitratech Holdings, Inc

Global Voices: Beating Bribery – Best Practice in Ethics and Conduct on the Global Stage

One of the biggest headaches for companies conducting business overseas still remains bribery and corruption. The grey area of what is deemed a fair gift, meal or payment against what might be constituted a bribe is a...more

The Volkov Law Group

NAVEX Global’s 2019 Definitive Corporate Compliance Benchmarking Report

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NAVEX Global recently released an important compliance report – 2019 Definitive Corporate Compliance Benchmarking Report.  NAVEX’s report contains a number of interesting findings and brings together several current...more

Thomas Fox - Compliance Evangelist

Day of Reckoning for KPMG-Failures in Ethics

The day of reckoning was here for KMPG and I do not think that anyone could have imagined how bad it would be for the firm. Last week the Wall Street Journal (WSJ) reported last week that KPMG was preparing to pay up to $50...more

Thomas Fox - Compliance Evangelist

All My Sons and What is Ethics?

If businesses were to understand that if they engage in bribery and corruption, the impact is much larger than simply the bribe they pay for the business opportunity. It can literally ruin the lives of many more people....more

The Volkov Law Group

Lessons Learned and Trends from MTS FCPA Enforcement Action and Criminal Indictment of Karimova and Akhmedov (Part III of III)

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The MTS FCPA enforcement action stands as one of several significant prosecutions in FCPA history. The breadth and depth of MTS’ corruption scheme stands as another example of systemic bribery cultures. The details of the...more

Thomas Fox - Compliance Evangelist

Wuthering Heights Week Part I: Integrity Agenda Framework

This year is the 200thanniversary of the birth of Wuthering Heights’ author, Emily Brontë. While her sister Charlotte received more acclaim as an author, I found Wuthering Heights to appeal much more greatly to my dark side. ...more

The Volkov Law Group

Corporate Character and Lack of Corporate Will

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Corporations experience numerous tests of character. Perhaps one of the most important is how the company responds when facing potential misconduct. ...more

The Volkov Law Group

Time for Companies to Establish an Independent Corporate Ombudsman

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Corporate commitment to speak up cultures is suffering. The Ethics and Compliance Initiative’s recent Global National Business Ethics Survey contained a critical finding – corporate instances of retaliation against employee...more

Thomas Fox - Compliance Evangelist

Reflections on Week of Compliance in Brazil

I have finished up my week in Brazil and I wanted to end this week’s Brazil focused blog posts with some final thoughts and observations on the country’s burgeoning compliance scene....more

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