Anti-corruption enforcement is a slow-moving vehicle. Investigations into business bribery allegations can take years to resolve, even with the application of significant agency resources. Building up enough prosecutorial capacity to handle a reasonable caseload requires its own long-term effort, both institutionally and politically.… Continue Reading
All posts by Robert Clark
Several well-known lists rank colleges and universities in the United States. Rankings that take into account diverse factors — class size, teacher-to-student ratio, financial aid, campus social life — are useful as a relative assessment of quality and allow future students to evaluate which schools might be good matches for their own temperaments, needs, resources, and goals.… Continue Reading
TRACE recently published its annual Global Enforcement Report, which collects summary data regarding the state of transnational anti-bribery investigations and enforcement actions around the world. One of the standout facts in the report is that the number of companies subject to enforcement actions in 2019 was notably lower than in 2018—a 19 percent drop in U.S.… Continue Reading
We see it every year: A new edition of a corruption ranking is released, and the first thing people ask is which countries have moved up or down in ranking. It is common knowledge among compliance officers that a country’s position on such an index is just a starting point for a thorough corruption risk assessment, but there is still a danger that nuances will get lost in the high-level presentation of the data.… Continue Reading
Compliance professionals have many factors to consider when assessing the bribery risk of their companies’ proposed investments or engagements globally. Industries have different dynamics, companies have different business models, and business partners and intermediaries have different relationships and backgrounds.… Continue Reading
With a rise in global trade and a focus on international development, the past two decades have seen increased attention to the worldwide problem of corruption. With that attention have come efforts to measure the degree of corruption from one country to another.… Continue Reading
The release of TRACE’s Global Enforcement Report 2017 (GER) gives us a chance to reflect on large-scale trends in anti-bribery enforcement.
For the United States, after 2016’s record-setting pace of FCPA settlements, the question wasn’t so much whether there would be a slowdown, but only how slow it would get.… Continue Reading
Any company doing business abroad is going to face corruption risk. Businesses have a responsibility to know where those risks are and to decide how to confront them.
One response is simply not to do business in high-risk countries.… Continue Reading
Companies minimize the risk of corruption by adequately vetting their prospective representatives — typically by reviewing information about the financial interests and relevant connections of the intermediaries’ owners and key personnel, and screening those individuals for reputational and criminal-history issues.… Continue Reading