At the end of each Department of Justice press release about FCPA-related settlements, the DOJ generally thanks those who have assisted with the case, including the prosecuting attorneys, other agencies, and foreign governments. … Continue Reading
The Securities and Exchange Commission filed an administrative complaint against New York-based brokerage firm Windsor Street Capital and its former anti-money laundering officer John D. Telfer.
The ethics & compliance community already knows we’re going to hear lots of chatter in coming months about easing the burden of compliance with the Foreign Corrupt Practices Act.
We’ll probably see a new attitude at the Justice Department, shifting away from prosecuting organizations in favor of prosecuting individuals.… Continue Reading
In the prior post, we talked about reasonable goal setting that can turn into perverse incentives, leading to compliance and reputational disasters like Wells Fargo. In this post, we look at whether companies can contain the excesses of their incentive programs with controls.… Continue Reading
FCPA enforcement has always been bi-partisan, commanding principled support from both sides of the aisle. Is that about to change?
The Speaker of the U.S. House of Representatives recently announced plans to repeal a number of federal regulations, including the SEC’s requirement that oil, gas, and mineral companies disclose payments to foreign government in excess of $100,000.… Continue Reading
Earlier this week Richard Bistrong and Marc Hodak, writing for the FCPA Blog, considered how the Wells Fargo incentive system got so out of whack, and how this out-of-whackness contributed to the scandal around fraudulent account openings that has engulfed the bank since last August.… Continue Reading
The Securities and Exchange Commission charged two former executives at Och-Ziff Capital Management Group with orchestrating bribes across Africa that violated the Foreign Corrupt Practices Act.
Writing in The Guardian, the paper’s financial editor Nils Pratley recently summed up £671 million ($800 million) in fines meted out to Rolls-Royce, in the aftermath of the various corruption investigations, as “big, ugly and serious.”… Continue Reading
When Wells Fargo imposed a target of eight accounts per customer on its branches, the bank created an aspirational goal. Cross-selling is a proven method of encouraging growth and maximizing upside, with little incremental expense.… Continue Reading
The Fat Leonard scandal has decimated the U.S. Navy’s Pacific Command. So far, sixteen defendants have been charged in the case. They include an Admiral, five Commanders, a Captain, and a Petty Officer.… Continue Reading
Over the last five years, we have seen greatly increased coherence and consistency in anti-corruption compliance programs. But, individual corporate action has only limited ability to confront and address what two authors called “wicked problems” of systemic corruption.… Continue Reading