In her excellent book, Thieves of State, Sarah Chayes argues persuasively that foreign corruption is a threat to U.S. national security because it drives people to radical Islam. There is an additional aspect to this problem: corrupt regimes are a national security threat because they start wars in order to divert attention from their own corruption.… Continue Reading
All posts by Thomas Firestone
A new Russian law, which went into effect on January 1, 2013, affirmatively requires companies to establish compliance programs.
The law, which was added as Article 13.3 of a broader 2008 Law on Combatting Corruption, is entitled “The Requirement of Organizations to Take Measures to Prevent Corruption” and provides that organizations are required to develop and implement measures to prevent corruption and states that such measures may include the following:
… Continue Reading
(1) designating departments and officers responsible for preventing bribery and related offenses;
(2) developing mechanisms for cooperation with law enforcement authorities;
(3) developing and implementing standards and procedures designed to ensure ethical business conduct;
(4) adopting a code of ethics and professional conduct for all employees;
(5) establishing means for identifying, preventing and resolving conflicts of interest; (6) preventing the creation and use of false and altered documents.