While the DOJ substantially expanded corporate liability under the FCPA in recent years, many corporations remain unaware of the potential liability risks associated with corruption and human trafficking in employment chains.… Continue Reading
The International Labor Organization estimates that nearly 21 million people are victims of forced labor worldwide, working in industries ranging from agriculture to electronics manufacturing.
Julie DiMauro: A compliance plan to keep forced labor and human trafficking out of your supply chains
In January, the U.S. Supreme Court declined to consider an appeal by three companies — Nestle SA, Cargill Inc., and Archer Daniels Midland Co. — that sought to dismiss a lawsuit alleging they aided and abetted child slave labor on coca plantations in Africa.… Continue Reading
If you’re a compliance practitioner seeking to design an anti-corruption program consistent with all laws that apply to your company, you probably recognize the phrase “carries on a business, or part of a business, in any part of the United Kingdom.”… Continue Reading
Fashion Week 2015 begins on February 12 in New York. Compliance will certainly not be on the agenda and the fashion industry has never attracted the kind of regulatory attention “enjoyed” by industries that rely heavily on public sector sales.… Continue Reading
Leslie Caldwell, the chief of the DOJ’s criminal division, does well at explaining why enforcing the FCPA and fighting corruption is a priority for the United States. Here’s part of what she said Wednesday at ACI’s 31st international conference on the FCPA at National Harbor, Maryland:
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[C]orruption is far more insidious and harmful than can be measured numerically.… Continue Reading
The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued an advisory Thursday to help financial institutions detect and report suspicious activity that could be related to human smuggling or human trafficking.… Continue Reading
The DOJ filed a civil forfeiture complaint in Manhattan federal court last week targeting seven properties allegedly purchased in Dutchess County, New York by a Greek national using the proceeds of a long-running human smuggling operation.… Continue Reading
Acting Assistant Attorney General Mythili Raman of the Justice Department’s Criminal Division is leaving the agency Friday, March 21. But the 17-year DOJ veteran made time the day before her departure to speak to the Global Anti-corruption Compliance Congress in Washington, DC.… Continue Reading
As reported last week by the FCPA Blog, President Obama signed a groundbreaking Executive Order designed to strengthen protections against trafficking in persons in federal contracting.
Among other requirements, the Executive Order requires federal contractors and subcontractors to take the following actions:
President Obama on Tuesday ordered enactment within six months of new federal regulations requiring strict compliance with the government’s zero-tolerance policy on human trafficking.
Anyone supplying goods or services to the government will have to comply by ensuring they don’t use misleading or fraudulent recruitment practices; charge recruitment fees; confiscate, hold, or conceal identity documents of any kind; or fail to pay repatriation costs for certain employees.… Continue Reading