Compliance Tip of the Day: COSO Governance Framework: Part 4, Culture
Compliance Tip of the Day: COSO Governance Framework: Part 2, Oversight
Compliance Tip of the Day: COSO Governance Framework: Part 1, Introduction
Compliance Tip of the Day: Design - Centric Internal Controls
Compliance Tip of the Day: Lessons from Internal Control Failures
Compliance Tip of the Day: Internal Control Deficiencies
Compliance Tip of the Day: Assessing Internal Controls
Compliance Tip of the Day: COSO Objective 5 – Monitoring Activities
Compliance Tip of the Day: COSO Objective 4 - Control Information and Communication
Compliance Tip of the Day: COSO Objective 3 – Control Activities
Compliance Tip of the Day – COSO Objective 1 – Control Environment
Compliance Tip of the Day: Code of Conduct as an Internal Control
Compliance Tip of the Day: COSO Framework
Compliance Tip of the Day: Internal Controls for GTE
Compliance Tip of the Day: Board Oversight on Internal Controls
Compliance Tip of the Day: Internal Controls for Third Parties
Compliance Tip of the Day: Implementing Internal Controls
Compliance Tip of the Day: Risk Assessments and Internal Controls
Compliance Tip of the Day: Issues for Internal Controls in International Operations
Compliance Tip of the Day: Top 4 Compliance Internal Controls
On July 15, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement agreement with Interactive Brokers LLC (“Interactive Brokers”) violations of multiple U.S. sanctions...more
The SEC’s FCPA enforcement action against WPP presents a number of important lessons learned, ranging from third-party risk management, properly responding to employee complaints and red flags, and failure to integrate...more
Companies have had over one year to review and implement a sanctions compliance guidance program. This last year, however, has been difficult (to say the least) given the COVID-19 pandemic....more
Goldman Sachs has a new leadership role – unfortunately, it is for corruption. It would be a serious mistake to characterize or describe the Goldman corruption scheme as the result of a few, bad actors. Instead, Goldman...more
As companies move forward on third-party risk management programs, and as automated third-party risk solutions are being implemented, compliance professionals have to re-examine and re-balance the allocation of resources and...more
The Microsoft FCPA settlement, while not significant in the total penalty of approximately $25 million, provides some important instructions concerning distributor and re-seller risks and mitigation strategies. ...more
The SEC announced last week a $5 million FCPA settlement with Vantage Drilling International (“Vantage”), a Texas-based offshore drilling company. ...more
This week I have been considering the new developments in the long-running 1Malaysia Development Berhad (1MDB) scandal. These developments include a guilty plea by a former Goldman Sachs Group Inc. (Goldman Sachs) banker in...more
Today, I continue my exploration of the new developments in the long-running 1Malaysia Development Berhad (1MDB) scandal. Last week the US Department of Justice (DOJ) announced one guilty plea, one arrest and one indictment....more
Several years ago (or in the recent past as some would say), pre-acquisition due diligence was a major compliance focus for global companies that grew through aggressive merger and acquisition strategies. ...more
We continue our exploration of the Foreign Corrupt Practices Act (FCPA) enforcement action involving Panasonic Avionics Corporation (PAC) and its parent Panasonic Corporation (Panasonic). Today, I want to conclude with some...more
Welcome to the 2017-2018 edition of the Jones Day Anti-Corruption Regulation Survey. In 2017 and 2018 to date, there has continued to be an increasing awareness among multinational companies of the significance of...more
No one needs to be reminded about the importance of anti-corruption compliance. For global companies, anti-corruption risks are amongst the top 3 risks identified by corporate leaders....more
If you want to learn and read about managing third-party risks, you will have no trouble finding articles, white papers, webinars and more available to you on the Internet. And for good reason....more
The first FCPA enforcement action for 2017 landed with very little fanfare. The SEC reached a settlement with Mondelez International for $13 million. The facts surround the hiring of an agent in India and the failure of...more
In almost every Foreign Corrupt Practices Act (FCPA) enforcement action, there are nuggets to be gleaned for any Chief Compliance Officer (CCO) or compliance practitioner. All one has to do is look for them. Back in 2012,...more
No matter how you cut it – this was a big year in FCPA enforcement. Not just because of the large enforcement actions but the scope and depth of enforcement, remediation and compliance program demands....more
On December 9th, 2016, France officially enacted the Law on transparency, anti-corruption and economic modernization (so-called "Sapin II bill") which introduces the following key changes...more
Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more
I conclude my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the resolution of...more
The SEC, last week, announced its $5 million settlement with Key Energy. As always, FCPA settlements contain important examples of enforcement priorities and policies. Key Energy’s recent settlement is an example of the...more
A due diligence infrastructure is designed to demonstrate a company’s good faith commitment to compliance with anti-corruption laws by: identifying corruption risks; and mitigating such risks to ensure that the company does...more