In my practice, I frequently assist clients with risk assessments, program reviews, and developing improvements to their existing anti-bribery and anti-corruption compliance programs, policies and procedures. Based on some recent experience, here is a brief list of key improvements companies can make to their ABAC compliance programs now and the related questions they should be asking as part of that effort.… Continue Reading
Every compliance training session should include this warning: If you ever become involved with, see, or otherwise discover a potential FCPA violation, stop everything. Don’t clean your desk, empty the trash can, or clear your browser history.… Continue Reading
A survey by Saudi Arabia’s National Anti-Corruption Commission found that 67.8 percent of the respondents believe financial and state corruption is on the rise in the country.
Osman bin Salih al-Amir, a lecturer at Ha’il Teachers College, told Press TV the results also “show that 92.1 percent of Saudi nationals hold nepotism responsible for the spread of corruption in their country.”… Continue Reading
In any country, paying for travel for government officials, customers at state-owned enterprises, or customers at purely private enterprises can present corruption risks. Many worthy publications have addressed travel risks generally and how to minimize those risks, including establishing a true business purpose for the trip, ensuring transparency with the recipient’s organization, pre-approving a detailed itinerary to ensure that sightseeing/leisure does not predominate, paying expenses directly to vendors where possible, avoiding unnecessary stopovers or family members or friends accompanying, etc.… Continue Reading
Here’s a note from contributing editor Marc Alain Bohn about our post yesterday, discussing the DOJ’s recommendation that three CCI executives be sentenced to probation and not jail time.
In Marc Alain Bohn’s FCPA Docket yesterday, there was important news about three individuals facing sentencing in the Control Components Inc. case.
On February 1, prosecutors asked the court to sentence Mario Covino, Richard Morlok, and Flavio Ricotti to probation and no jail time.… Continue Reading
The former director of worldwide sales for Control Components Inc. was sentenced Thursday to 13 months home confinement and fined $20,000 for bribing Chinese officials.
Paul Cosgrove, 65, pleaded guilty in May to one count of violating the FCPA.… Continue Reading