In-house counsel, compliance officers and the external counsel who support them are trained to be risk averse when it comes to anti-corruption and other types of compliance, and with good reason.… Continue Reading
Corrupt payments are made to achieve important objectives — important enough to risk possible loss of reputation and criminal prosecution. The most common objectives are winning business, maintaining business, and executing transactions faster.… Continue Reading
The U.S. Treasury Department’s Financial Crimes Enforcement Network sets risk-based compliance obligations of U.S. financial institutions. FinCEN directs counter-measures against the countries with the highest risk and enhanced due diligence against others.… Continue Reading
The Federal Deposit Insurance Corporation (FDIC) issued guidance Wednesday encouraging its insured banks to take a risk-based approach in assessing individual customer relationships.
The FDIC said in its Financial Institution Letter that looking at risk on a case-by-case basis is better than declining to provide banking services to entire categories of customers.… Continue Reading
A new survey of general counsels and compliance officers found that 30% of companies in North America, Europe, and Asia stopped doing business with a partner because of corruption risks.
In response to Halliburton’s proposed acquisition of Expro, the U.S. Department of Justice recently thrust the concept of “a risk-based approach” to the forefront of anti-bribery compliance with Opinion Procedure Release 08-02.… Continue Reading