What the FTX is going on?
Let me bring you up to speed if you missed the news. There is a Pompeii-grade meltdown happening in the cryptocurrency world.… Continue Reading
Let me bring you up to speed if you missed the news. There is a Pompeii-grade meltdown happening in the cryptocurrency world.… Continue Reading
Netflix recently released a new docuseries on the FIFA corruption scandal. The four-part series delves into the history and mechanics of how the organization was corrupted.… Continue Reading
Along with work-from-anywhere and quiet quitting, the pandemic gave us “bring your whole self to work.” But what does being real at work look like? And is workplace authenticity a good idea for compliance?… Continue Reading
At the gatehouse, the security guard passed me a Novartis visitor’s badge, and I turned to walk down Fabrikstrasse – the campus’ central boulevard. Two thoughts popped into my head: I think I’m too early (I was) and I hope these people are friendly (they were).… Continue Reading
The UK subsidiary of Swiss mining giant Glencore was ordered to pay £281 million ($314 million) in the United Kingdom on Thursday for bribes in Nigeria, Cameroon, Ivory Coast, Equatorial Guinea, and South Sudan.… Continue Reading
Corporate subsidiaries only act on someone else’s say so. The drafters of the FCPA knew that, and that’s why the FCPA prohibits offering to pay, paying, promising to pay, or authorizing the payment of money or anything of value to a foreign official for an improper purpose.… Continue Reading
New and old corporate dishonesty stories, such as Theranos, Wirecard, and Wells Fargo, highlight a fundamental weakness. Irrespective of the industry or the business maturity, the wrongdoing escalates when the lines of defense that should protect the organization from risk become Teflon barriers to any accountability process.… Continue Reading
Employers have been using technology to keep an eye on workers for at least a decade. And when the pandemic shifted nearly everyone to work-from-anywhere, monitoring went through the roof.… Continue Reading
Last week, SFO head Lisa Osofsky told British lawmakers that she regretted the agency’s “damaging relationship” with an American private investigator during a major corruption probe into oil consultancy Unaoil, which ultimately led to three UK convictions being overturned.… Continue Reading
At 50, I sat in prison for violating the FCPA, among other offenses, due to no one’s fault but my own. At 40, I had sunk deep into the throes of drug addiction, which is not why I landed in prison at 50, but the addiction was a step in a series of awful decisions and contributed to my sense of narcissism and impunity.… Continue Reading
An FCPA anti-bribery offense requires five essential elements: (1) Corruptly (2) paying or promising to pay (3) anything of value (4) to a foreign official (5) for the purpose of obtaining or retaining business or securing any improper advantage.… Continue Reading
The lone exception written into the FCPA allows bribes for “routine governmental action . . . which is ordinarily and commonly performed by a foreign official.” That sounds simple, but it’s not.… Continue Reading