Corruption is no longer the U.S. government’s persona non grata – reluctantly acknowledged and somewhat ignored outside FCPA enforcement. The President’s summer National Security Memorandum and recent U.S. Strategy on Countering Corruption place governmental and other anti-corruption activities front and center.… Continue Reading
Posts Tagged: ISO 37001
I read the recent FCPA Blog post “Can we really ‘measure’ compliance?” with great interest. Richard Cassin touched on one of the essential areas the compliance community needs to work together to improve our approach.… Continue Reading
On January 25, 2017, Eni Corporation announced its ISO 37001 certification. The press release stated that “certification confirms the quality of the system of rules and controls aimed at preventing corruption, developed by Eni since 2009 in line with the principle of ‘zero tolerance’ expressed in its Code of Ethics.”… Continue Reading
2018 was an eventful year in ISO 37001’s adoption journey. The anti-bribery standard’s flexibility was demonstrated through a variety of first-time (for ISO 37001) public and private sector uses.
The Brazilian and Danish prosecutors’ use of ISO 37001 in bribery settlement agreements, and the Korean Pharmaceutical and Bio-Pharma Manufacturers Association assistance to its 194 members with a phased ISO 37001 adoption approach, for example. … Continue Reading
My prior post for the FCPA Blog suggested that changes are needed to the ISO 37001 anti-bribery management system before countries, agencies, and companies move forward with large-scale adoption.
One of my suggestions in particular — that ISO replace certification with a process for obtaining reviews of compliance programs — attracted thoughtful opposing comments and some criticism.… Continue Reading
In November last year the Shenzhen Institute of Standards and Technology awarded the first ISO 37001 Anti-Bribery Management System certificate in China, an important milestone in the country’s persistent fight against corruption.… Continue Reading
2017 proved to be a blockbuster year for the FCPA and anti-bribery and corruption (ABC) enforcement at large.
From sustained record levels of enforcement (some 11 penalties levied, totaling $1.92 billion; the second largest year on record) to significant developments via the newly announced FCPA Corporate Enforcement Policy by the Department of Justice in late November, businesses are on notice that this remains a significant regulatory priority.… Continue Reading
In Deputy Attorney General Rosenstein’s recent announcement of a new FCPA Policy, he highlighted three hallmarks of a Policy effective compliance program: fostering a culture of compliance; dedicating sufficient resources to compliance activities; and ensuring that experienced compliance personnel have appropriate access to the board.… Continue Reading
Hui Chen recently published a post sharing her opinions on the ISO 37001 Anti-Bribery Management Standard and ISO 37001 certification. She made some important points.
She also asked questions and drew comparisons that should be evaluated in the context of how the ISO 37001 certification process occurs, and what it means for companies and organizations seeking it.… Continue Reading
After news broke that the U.S. Department of Justice was investigating Uber’s potential violations of the Foreign Corrupt Practices in late August, the National Law Review wrote, “In our experience, once DOJ begins learning about a particular industry in such an investigation, the investigation will expand to other players within the industry.… Continue Reading
Is my anti-corruption program effective or not effective? In the United States, companies only receive the definitive answer to that question in worst case scenarios — at the back end of a governmental program evaluation, typically while under FCPA scrutiny by the DOJ.… Continue Reading