There is a portion of the DOJ’s Evaluation of Corporate Compliance Programs that has received surprisingly little play in FCPA compliance circles. Under the heading “Risk-Based Training,” the DOJ poses a series of questions companies will need to answer.… Continue Reading
After more than two decades of forensics practice, I know that during any anti-corruption compliance assessment, I’ll want to spend time not only with personnel from the accounting and compliance groups, but also with human resources.… Continue Reading
In the wake of Malaysia’s 14th General Elections in May this year, an important piece of legislation seems to have slipped under the radar.
The Malaysian Anti-Corruption Commission Act 2009 was amended to introduce corporate liability for bribery and corruption for the first time.… Continue Reading
I recently wrote on the FCPA Blog about anti-corruption internal controls in China related to the Bruker Corporation settlement. That post focused mainly on policy translation, local language training, and independent compliance oversight of local operations.… Continue Reading
In the world of anti-corruption internal controls, there is no “one-size-fits-all” model. Ideally, design and implementation of such controls should be thoughtful, rigorous and based on a robust and re-performable corruption risk assessment. … Continue Reading
Since August 2012, there has been a lot of discussion in anti-corruption circles about Oracle’s settlement with the SEC, including here. Much of the past discussion has focused on the fact that the SEC charged Oracle with books & records and internal controls FCPA violations without an attendant allegation of bribery.… Continue Reading