Last month the international business community, in the form of the business B20 group, put out a call for G20 nations to develop national-level anti-corruption strategies (June 22, 2018, B20 and C20 joint statement on implementation of national anti-corruption strategies).… Continue Reading
Lindsay Columbo’s excellent post for the FCPA Blog (“How did due diligence ever become so complicated?”) articulated a set of thought-provoking observations that many of us working in the financial and legal sector, and who have compliance and KYC obligations, have been pondering for some time.… Continue Reading
Political developments in Malaysia should provide a governance “wake up call” for international companies operating in the country, which urgently need to review their relationships with local business partners. If they did not conduct integrity due diligence before entering these relationships, they should consider doing so now.… Continue Reading
Job Title: Executive Director, Global Compliance
Location: Wilmington, Delaware USA
Description: Incyte Corporation’s Global Compliance Group is looking for an Executive Director, Global Compliance. This position will include management and oversight of Incyte’s Global Corporate Compliance Program, with significant interaction with Incyte’s Global and Regional Sales and Marketing, Legal, Information Technology, Medical Affairs, Product Strategy, Research and Development, and other company departments.… Continue Reading
David Bligh’s recent post for the FCPA Blog asked a provocative question: Did the Corruption Perceptions Index correlate with World Cup fouls?
To answer this question, he did a linear regression analysis with the average number of fouls committed by each team that participated in the last World Cup versus the ranking obtained by those countries in Transparency International’s 2017 Corruption Perceptions Index.… Continue Reading
Want any greater evidence of not only the effectiveness of compliance but its now mandatory nature as a business process going forward? Look no further than the marketplace.
Two recent announcements of significant venture capital funding made clear that companies which deliver products and services in the compliance arena are viewed as prime business opportunities.… Continue Reading
The prosecutor who oversees the criminal division’s FCPA unit said the DOJ wants corporate acquisitions to happen and doesn’t want the “specter of enforcement to be a risk factor that impedes such activity by good actors.”
Deputy assistant attorney general Matthew Miner was speaking Wednesday in Washington at ACI’s global forum on anti-corruption compliance in high risk markets.… Continue Reading
In a novel, even if rather obscure manner, the Trump Administration has found a new way to put America first.
It has long been recognized that a critical principle of good governance and compliance is the implementation, promotion and communication of the right tone at the top. It is the fundamental groundwork in setting a company’s culture and is arguably the most important principle in the prevention and detection of bribery and unethical conduct.… Continue Reading
Two days ago, one of my senior analysts burst into my office proclaiming, “You can’t imagine what I found and how I found it!” My interest was piqued so he took a few minutes to explain the situation.… Continue Reading
In the closely-watched criminal case against Chi Ping Patrick Ho pending in the Southern District of New York, the court last week rejected the defendant’s argument that an indictment cannot stack FCPA charges by alleging competing bases for jurisdiction.
Ho, the head of a Hong Kong-based NGO, was indicted (pdf) in November 2017 for allegedly offering $2 million to the president of Chad in order to facilitate oil rights for a Chinese energy company and $500,000 to the foreign minister of Uganda to secure a banking deal for the company. In April, he filed a motion to dismiss certain of the FCPA counts.… Continue Reading