Episode 66 -- Gifts and Hospitality Compliance and Best Practices
Day 11 of One Month to More Effective Internal Controls-Internal Controls for Gifts, Travel and Entertainment
FCPA Compliance and Ethics Report-Episode 165-BHP FCPA Enforcement and Lessons Learned for the Compliance Practitioner
2024 saw another strong year of Foreign Corruption Practices Act (FCPA) enforcement actions from the United States Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). There were 15 resolutions with...more
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
Herbalife’s FCPA settlement is another one for books – the wreckage left includes two criminal indictments for Chinese officials who may never be apprehended, along with $123 million in penalties....more
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
Ericsson’s FCPA settlement is in the books (not the books and records). But it casts a significant shadow across the FCPA landscape. A pervasive and systemic culture of bribery is defined to reflect senior executive...more
Last week, DOJ announced the indictment of two former Herbalife executives in China for participating in a bribery scheme over a ten-year period. Herbalife, a multi-level marketing company, was not charged and its...more
On September 4, 2019 the Department of Justice (DOJ) announced a $15.4 million settlement with pharmaceutical company Mallinckrodt ARD LLC (Mallinckrodt) to resolve alleged violations of the Anti-Kickback Statute (AKS) in two...more
The Department of Justice (DOJ) recently resolved two health care fraud cases – one criminal and one civil – that demonstrate the government’s continued scrutiny of lavish meals and “speaker’s bureaus” sponsored by...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
Intuitively, Israeli companies and their directors would likely assume that their businesses are immune to investigation and the assessment of penalties by US regulators that are separated by a vast ocean and located more...more