What’s it take for us to have a great week? Four excellent guest posts will do it every time.
In case you missed any of them, Micheal Volkov looked at the new UK Bribery Act. He advised everyone to take a deep breath and remain calm. UK prosecutors, he said, aren’t likely to go off the deep end so the rest of us shouldn’t either.
Ryan McConnell and Charlotte Simon analyzed the annual crop of deferred prosecution agreements and shared some surprising results, like this: “Despite the clear benefits from an effective compliance program, statistics from the U.S. Sentencing Commission reveal that virtually every company convicted of violating federal law lacks an effective compliance program.” History is unanimous, so get on board with an effective compliance program.
Jeff Kaplan’s take on the Alcatel-Lucent criminal information was fresh and practical. He said that among the company’s violations of the FCPA’s internal controls requirements was the failure “to provide appropriate incentives to perform in accordance with [its] compliance and ethics program.” How many companies could be making that same mistake today? Many, we think.
Finally, Tom Fox brought his usual enthusiasm to a post about a new book on the BP Deepwater Horizon disaster. Tom turned his review into a short, useful lesson on — you guessed it — compliance.
We thank them all for making this an outstanding week.
We also want to thank Peter Henning for mentioning us in his New York Times DealBook column this week about sovereign wealth funds and the FCPA. We owe Prof Henning a double portion of gratitude — his inspiration helped launch the FCPA Blog.