Per diems. We in the FCPA bar love to hate them, and with good reason. Who likes the idea of giving cash to foreign officials? If there’s anything that should rankle the anti-corruption specialist, this is it. … Continue Reading
Heads up: The six-month anniversary in your new position will arrive in a flash.
If you were hired as part of your organization’s response to a serious corruption allegation, you may still be in fire-fighting mode at this point, but starting to emerge for air.… Continue Reading
Matt Kelly’s post for the FCPA Blog about ISO 37001 — the draft standard for anti-bribery management systems– was a helpful introduction. We’re both members of the ISO 37001 U.S. Technical Advisory Group.… Continue Reading
The DOJ and SEC haven’t used the word “scalable” to describe an effective compliance program. But they’ve described scalability when talking about what’s needed.
For example, part of the job of the DOJ’s new compliance counsel is to help “assess a company’s program, as well as test the validity of its claims about its program, such as whether the compliance program truly is thoughtfully designed and sufficiently resourced to address the company’s compliance risks.”… Continue Reading
Boards of directors in global companies are showing an increased interest in establishing financial crime committees and hiring notable experts to advise them.
Several well-publicized enforcement actions have provided the impetus by requiring companies to establish such board-level committees and add to their financial crime expertise.… Continue Reading