Anti-corruption enforcement is a slow-moving vehicle. Investigations into business bribery allegations can take years to resolve, even with the application of significant agency resources. Building up enough prosecutorial capacity to handle a reasonable caseload requires its own long-term effort, both institutionally and politically.… Continue Reading
TRACE held its annual U.S. Forum in Washington, DC, this week. More than 120 companies gathered to benchmark their programs and to hear from an extraordinary array of government, law firm and in-house speakers.… Continue Reading
If your offices, like ours, are currently filled with colorful jerseys and employees furtively checking scores on their phones, you know that soccer (or football or futball) has the attention of much of the world right now.… Continue Reading
On May 24, I wrote a post for the FCPA Blog about TRACE’s concerns that Article 10 of the new EU General Data Protection Regulation (GDPR) presents an obstacle to anti-bribery due diligence of third parties, and how we have advocated for an EU-wide, or at least a national-level, solution.… Continue Reading
The release of TRACE’s Global Enforcement Report 2017 (GER) gives us a chance to reflect on large-scale trends in anti-bribery enforcement.
For the United States, after 2016’s record-setting pace of FCPA settlements, the question wasn’t so much whether there would be a slowdown, but only how slow it would get.… Continue Reading
One of the main components of a comprehensive anti-bribery risk assessment is evaluating the risks pertaining to a given country. Both the FCPA Guidance and the UK Bribery Act 2010 Guidance highlight country risk as one of the key areas that should be addressed when conducting an assessment.… Continue Reading
I have not had sight of the TRACE reports into Unaoil but no doubt in time they will become public. I am confident that TRACE did what it was contracted to do and exercised skill and care in so doing.… Continue Reading