As I spent some time this morning trolling through a few dozen articles and opinion pieces about the Unaoil scandal, I was drawn to a Huffington post article detailing the roles of two large commercial banks. … Continue Reading
While clear policies on charitable contributions are important, the controls implementing these policies are equally critical to an effective compliance program.
Which type or types of controls are used in emerging markets is a function of the local level of corruption risk, the nature of the company’s intended contribution, the nature of the company’s business, and the size and complexity of its business.… Continue Reading
At November’s 32nd ACI Foreign Corrupt Practices Act conference in Washington, DC, the DOJ’s new Compliance Counsel, Hui Chen, emphasized that compliance programs need to be real and not just paper programs. … Continue Reading
Companies increasingly understand the importance of strong vendor-compliance programs, but costly enforcement actions stemming from supply-chain mismanagement remain.
Two experts have a few training, monitoring and evaluating tips to share with us.… Continue Reading
We always enjoy it when Pete from DC drops by the blog. He’s a veteran compliance professional and thinks deep thoughts about the Foreign Corrupt Practices Act. Lately, he told us, he’s been thinking about audit rights — the kind mentioned in our recent post about joint ventures.… Continue Reading