A recent scandal at a major Chinese public hospital revealed that many of the public hospitals across the country outsource their medical services to private companies and employ doctors as independent contractors. That could raise doubts about some public hospital doctors in China being “foreign officials” under the FCPA.… Continue Reading
China has chosen seven audit firms including PwC, BDO, and Grant Thornton to examine the overseas assets of major state-owned enterprises (SOEs) following an open tender held last month.… Continue Reading
In the world of anti-corruption internal controls, there is no “one-size-fits-all” model. Ideally, design and implementation of such controls should be thoughtful, rigorous and based on a robust and re-performable corruption risk assessment.
There are, of course, a number of sources of high-level guidance available, ranging from the DOJ / SEC FCPA Guidance, the OECD’s Good Practice Guidance on Internal Controls, Ethics, and Compliance, Transparency International’s Business Integrity Toolkit, and the UK Ministry of Justice’s Guidance about procedures to prevent bribery, among others.… Continue Reading
The Securities and Exchange Commission Monday charged Bruker Corporation with violating the Foreign Corrupt Practices Act by paying for sightseeing trips and shopping expenses for Chinese government officials responsible for buying the company’s products.… Continue Reading
Business opportunities in China abound. But as anyone who reads the FCPA Blog knows, compliance there can be particularly challenging.… Continue Reading