Blog Posts Tagged with "FCPA"

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DOJ Guidance on FCPA Compliance Programs

November 12, 2010 Added by:Thomas Fox

The information included these collective Corporate Compliance Programs provides the FCPA compliance practitioner with the most current components that the Department of Justice believes should be included in a FCPA compliance program...

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Proposed Amendments to the FCPA

November 05, 2010 Added by:Thomas Fox

After his speech to the Compliance Week Annual Conference last May, Assistant Attorney General for the Criminal Division of the US Department of Justice, Lanny Breuer, took several questions from the audience. One of his more interesting responses was regarding facilitation...

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Information Based Enterprise Plagued by Fraud

October 27, 2010 Added by:Thomas Fox

According to the 2010 Kroll survey, 88% of companies have been victims of fraud in the past year. Information-based industries reported the highest incidence of theft of data over the past 12 months - these include financial and professional services, technology, media and telecoms...

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Ongoing FCPA Compliance Assessments

October 22, 2010 Added by:Thomas Fox

This posting will review the specifics of each of these documents and will provide to the compliance and ethics practitioner some ideas on how to implement what each of these protocols stress is key component of any best practices compliance program...

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Managing Foreign Business Partners and the FCPA

October 15, 2010 Added by:Thomas Fox

The Wall Street Journal reported that the US Department of Justice was investigating allegations of possible bribery in Yemen by Schlumberger Ltd., in connect with their 2002 agreement with the Yemen government to create a national exploration data-bank for the country’s oil industry...

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Getting Your Arms Around FCPA Due Diligence

October 08, 2010 Added by:Thomas Fox

Companies need to bring resources to bear to comply with the FCPA while continuing to do business. This can be particularly true in the area of performing due diligence on foreign business partners or vendors in the supply chain...

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Examining FCPA Investigation Protocols

September 29, 2010 Added by:Thomas Fox

Detailed written procedure to ensure there is complete transparency on the rights and obligations of all parties once an allegation is made. This allows the Compliance Department to have not only the flexibility but also the responsibility to deal with such matters...

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When Does Compliance and Ethics No Longer Matter?

September 17, 2010 Added by:Thomas Fox

While recognizing that in certain professional service businesses such as auditing, integrity is everything. Conversely in other types of businesses where profit motives may not be connected to good ethics, an emphasis on integrity may not jeopardize the business...

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Reductions in FCPA Fines

September 04, 2010 Added by:Thomas Fox

Using a regression analysis, Hinchey concluded that those companies which did so voluntarily paid higher fines than companies which did not self disclose their FCPA violations to the DOJ. This evidence was contrary to the conventional wisdom that a company receives a benefit from self-disclosure...

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FCPA – Tone at the Top and in the Middle

August 23, 2010 Added by:Thomas Fox

High-level personnel of an organization shall be knowledgeable about the content and operation of the compliance and ethics program… and shall promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law...

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Hotlines as an FCPA Compliance Tool

August 12, 2010 Added by:Thomas Fox

The proper maintenance of a Hotline does not only allow a company to track compliance issues as they come into the system and document the responses, they can also use this information as an ongoing audit of the FCPA compliance system...

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Compelled Giving and the FCPA

August 02, 2010 Added by:Thomas Fox

We believe that the underlying facts of the Opinion Release referenced demonstrate that the Department of Justice (DOJ) has recognized that compelled giving is a situation that is faced by US companies doing business overseas, if not on a regular basis, but certainly one that is not unknown...

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Hewlett Packard and Lots of FCPA Red Flags

July 17, 2010 Added by:Thomas Fox

In April 2010 the Wall Street Journal reported that HP’s German subsidiary made payments to agents which eventually ended up in the hands of some unknown Russians, in order to obtain the contract to supply computers to the Russian Prosecutor’s Office...

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DOJ on an Effective FCPA Compliance Program

June 19, 2010 Added by:Thomas Fox

At the recent Compliance Week 2010 Annual Conference one of the issues discussed by Assistant Attorney General, for the Criminal Division of the US Department of Justice, Lanny Breuer, was what the Department of Justice (DOJ) might consider as an “effective compliance and ethics program” under the Foreign Corrupt Practices Act (FCPA), if a FCPA violation occurs and a company’s compliance pro...

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DOJ Weighs-In at Compliance Week

June 03, 2010 Added by:Thomas Fox

Assistant Attorney General for the Criminal Division of the U.S. Department of Justice (DOJ), Lanny Breuer gave the final day’s keynote speech at the Compliance Week 2010 Conference.

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Hewlett-Packard, Watergate and the FCPA

May 18, 2010 Added by:Thomas Fox

It has been many years since Watergate and the many lasting legacies which occurred from that break-in of the Democratic National Committee. Indeed one of those legacies is the Foreign Corrupt Practices Act (FCPA) itself. This article will focus on one of the more mundane legacies, that of the “Watergate deposition”, which was, for those of us who were riveted by the hearings of the ...

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