Two years after the Bribery Act 2010 came into force, the hysteria surrounding the Act has abated. There are fewer media pundits pronouncing the end of UK plc as we know it and there are fewer newly invented “legal experts” opining on an area they knew little or nothing about but which they saw as a potential earner to fill the gaping hole left by declining litigation and commercial transactions.… Continue Reading
The DOJ and SEC today released a 120-page FCPA resource guide.
It’s available in pdf here.
The foreword, signed today by the DOJ’s Lanny Breuer and the SEC’s Robert Khuzami, says:
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The Guide is an unprecedented undertaking by DOJ and SEC to provide the public with detailed information about our FCPA enforcement approach and priorities.
Transparency International’s July 2012 ranking of top compliance programs has European companies in the top spots. Many prominent U.S. based companies, along with Japanese and Chinese companies, rank amongst the lowest.… Continue Reading
It discusses the adequate procedures defense under the UK Bribery Act and explores suggestions for a similar kind of compliance procedures defense under the FCPA. … Continue Reading
Payments to government employees in exchange for the performance of a non-discretionary function such as issuance of a license or a permit occur far more often than bribes to government officials in exchange for assistance in winning a government contract.… Continue Reading
We spoke this week with Billy Jacobson, left, the former assistant chief for FCPA enforcement at the DOJ.
Next month, Richard Alderman will step down as head of the U.K.’s Serious Fraud Office. During his eventful four-year tenure, Alderman oversaw the introduction of the U.K. Bribery Act. He also waged a successful struggle to prevent the SFO from being absorbed by the U.K.’s… Continue Reading