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White Collar Crimes Risk Assessment Due Diligence

Thomas Fox - Compliance Evangelist

Adventures in Compliance: The Novels – The Hound of the Baskervilles, Introduction and Compliance Lessons Learned

In this new season of Adventures in Compliance, host Tom Fox takes a deep dive into the Sherlock Holmes novels. Throughout this season, Tom will delve into each novel in a four-part series. The four novels we will consider...more

A&O Shearman

Practical tips for large organisations to ensure reasonable procedures to prevent fraud are in place

A&O Shearman on

We distil key practical takeaways from the UK Government’s official guidance on the corporate criminal offence of failure to prevent fraud (the Guidance). Businesses and compliance teams will be working to review and...more

The Volkov Law Group

The Magnificent Seven: Important Ways to Mitigate Your Third-Party Sanctions Risks (Part IV of IV)

The Volkov Law Group on

It may seem like a Herculean task — but it can be done.  I regularly opine that mitigating sanctions risks for your third-party population is an easier task than doing so for your anti-corruption risks.  One big reason —...more

American Conference Institute (ACI)

Practical Implications of the Department of Justice’s M&A Safe Harbor Policy

In early October 2023, Deputy Attorney General (DAG) Lisa Monaco announced a “new” (but not new) Department of Justice (DoJ) policy intended to incentivize acquiring companies to voluntarily self-disclose criminal misconduct...more

K&L Gates LLP

Why Corporates Are Now More Likely to Face Criminal Prosecution for the Actions of Their Employees

K&L Gates LLP on

Significant Expansion to Corporate Criminal Liability Becomes Law in the United Kingdom - On 26 October 2023, the Economic Crime and Corporate Transparency Act (the Act) became law. Under the Act, corporations will become...more

Morgan Lewis

UK Serious Fraud Office Emphasizes Importance of Compliance Programs

Morgan Lewis on

In a recent update to its internal guidance, the UK Serious Fraud Office provides insight into the general approach its investigators may take for evaluating organizations’ compliance programs—an approach similar to that of...more

Thomas Fox - Compliance Evangelist

New Year, New Compliance Game Plan

With a new year, many folks have been promoted to the CCO chair. What should be your plan starting the new year and a new job. The answer is found in the  eBook Compliance Program Game Plan by myself and Jonathan Marks. ...more

Thomas Fox - Compliance Evangelist

The OFAC Compliance Framework: Element 2 – Risk Assessment

I am in a multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand and implement some of the key concepts of the Framework into your...more

The Volkov Law Group

The Importance of Pre-Acquisition FCPA Due Diligence (Part II of III)

The Volkov Law Group on

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

Jones Day

Anti-Corruption Regulation Survey of 41 Countries 2017–2018

Jones Day on

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

The Volkov Law Group

ISO 37001: Risk Assessments, Employees, and Due Diligence Requirements (Part IV of V)

The Volkov Law Group on

In Part IV of my series on ISO 37001, I examine requirements relating to risk assessments, design of policies and procedures, and due diligence requirements. Section 4.5 sets out requirements for conducting risk...more

Orrick, Herrington & Sutcliffe LLP

New French Anticorruption Legislation Affecting Large French and Foreign Groups of Companies and Their Top Management

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

Skadden, Arps, Slate, Meagher & Flom LLP

"The New UK Corporate Offence of 'Failure to Prevent the Facilitation of Tax Evasion': Implications for Fund Managers and...

The U.K. government expands its crackdown on tax evaders and the persons who assist them, by targeting businesses who fail to prevent tax evasion....more

Thomas Fox - Compliance Evangelist

Hallmark 10 – Mergers and Acquisitions: Pre-Acquisition Due Diligence and Post-Acquisition Integration

The FCPA Guidance notes that one of the ten hallmarks of an effective compliance program is around mergers and acquisitions (M&A), in both the pre and post-acquisition context. A company that does not perform adequate FCPA...more

The Volkov Law Group

Building a Due Diligence Infrastructure (Part IV of IV)

The Volkov Law Group on

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

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