[…] charged him.4 The issue, as he sees it, arises from a chart at the end of paragraph 2: COUNT APPROXIMATE MEANS AND INSTRUMENTALITIES OF DATE INTERSTATE AND INTERNATIONAL COMMERCE Two April 21, 2014 COBURN email to SCHWARTZ, CC#1, and CC#2 requesting a call the next morning to follow up from their discussion in their […]
Search Results for: label/York International – Page 329
The Justice Department Monday published a new version of its guidance on how it evaluates compliance programs when making corporate charging decisions.
Mexico City-based law firm Litigio Estratégico y Compliance has updated the Spanish translation of the DOJ’s June 2020 Guidance for the Evaluation of Corporate Compliance Programs.
Paris-based compliance consultancy Compliance For Good has translated the DOJ’s June 2020 Guidance for the Evaluation of Corporate Compliance Programs. The unofficial translation includes both English and French and can be downloaded here. Our thanks to Cecilia Fellouse-Guenkel, founder and manager of Compliance For Good, for making this resource available to our readers. Christ Mbondo […]
[…] Justice (DOJ) and the Securities and Exchange Commission (SEC) available at https://www.justice.gov/criminal-fraud/file/1292051/download . ï· Recommendation of the Council for Further Combating Bribery of Foreign Public Officials in International Business Transactions, amended by the Organization for Economic Co-operation and Development (âOECDâ) Council on November 25, 2021 available athttps://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0378 . ï· Anti-Corruption Ethics and Compliance Handbook […]
[…] associations of third-party partners, including the agents, consultants, and distributors that are commonly used to conceal misconduct, such as the payment of bribes to foreign officials in international business transactions. Prosecutors should also assess whether the company knows the business rationale for needing the third party in the transaction, and the risks posed by […]
This year the SEC has already awarded $114 million to whistleblowers, nearly twice the amount than for all of 2019. Three awards in 2020 are among the ten biggest SEC payouts ever, including last week’s $50 million award to a former BNY Mellon currency trader. Would-be SEC whistleblowers and their lawyers should be tingling with […]
[…] Translation Courtesy of Ritch Mueller Traducción No Oficial Cortesía de Ritch Mueller 16 to conceal misconduct, such as the payment of bribes to foreign offi cials in international business transactions. Un programa de compliance bien diseñado debe aplicar debida diligencia basada en los riesgos de sus relaciones con tercer os . Aun cuando el […]
The Treasury Department’s Office of Foreign Assets Control issued a new advisory Thursday warning banks, insurance companies, negotiators and others about sanctions risks from helping victims make ransomware payments.
The Ethics and Reputation Society of Turkey has translated the DOJ’s June 2020 Guidance for the Evaluation of Corporate Compliance Programs.