Most FCPA enforcement actions involve intermediaries. By prioritizing risk and harnessing inherent capabilities of a compliance program, it’s possible (and often necessary) to build an effective third party compliance program despite resource limitations.… Continue Reading
A Honduran citizen pleaded guilty in federal court in Louisiana Thursday to laundering $1.3 million in bribe money, along with assets his brother looted from the Honduran Institute of Social Security.… Continue Reading
At the heart of any prospective self-disclosure to the DOJ is a robust internal compliance review program. Companies, no matter how large or small, should be looking to do two things: evaluate past practices and ensure ongoing compliance.… Continue Reading
It may not be intuitive for a compliance department to dig into the completeness, consistency and organization of a company’s employee and customer data. But the integrity of the data impacts almost every automated compliance solution a company implements.… Continue Reading
A federal judge in Miami sent an official of Aruba’s state-owned telecomms company to prison for three years for moving bribe money from Florida to Aruba and Panama.
Egbert Yvan Ferdinand Koolman, 49, a Dutch citizen living in Miami, was also ordered pay $1.3… Continue Reading
One of the biggest boiler-room fraudsters in UK history hid his operation behind multiple layers of offshore shell companies set up by the now-defunct Panama Papers law firm, Mossack Fonseca.… Continue Reading
If your offices, like ours, are currently filled with colorful jerseys and employees furtively checking scores on their phones, you know that soccer (or football or futball) has the attention of much of the world right now.… Continue Reading
An asset-freezing injunction can be an important tool in fraud recovery litigation. Because it must be obtained ex parte, that is, without notice to the alleged fraudster, the justice system treads very carefully in balancing the rights of the accused and the accuser.… Continue Reading
How do compliance officers get to know what they don’t know, especially in places where values are challenged, where local practices conflict with the rules, and where the line between what’s a permissible activity and what’s a violation can look blurry?… Continue Reading
One of the most common discussions in the ethics and compliance community today revolves around the idea of using corporate values to foster ethics in organizations. Though this conversation has helped practitioners move away from a check-the-box compliance approach, practices based on corporate values have unwittingly created a check-the-box approach to ethics, obscuring the disconnect between external values and what the organization actually values.… Continue Reading
Only yesterday they were pimply FCPA nerds. But a strange thing happened. They morphed into the cool kids.
Today’s compliance officers are famous and wanted.
Here’s some evidence.