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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Posts Tagged: UK Bribery Act

Image Sensing discloses Poland investigation

Minnesota-based Image Sensing Systems said Tuesday an investigation by police in Poland has triggered an FCPA and U.K. Bribery Act investigation.

The developer of traffic enforcement solutions said two employees of its Poland unit have been charged with criminal violations related to a project in the City of Łodź, Poland.… Continue Reading

New Russia law goes beyond FCPA, Bribery Act

A new Russian law, which went into effect on January 1, 2013, affirmatively requires companies to establish compliance programs.

The law, which was added as Article 13.3 of a broader 2008 Law on Combatting Corruption, is entitled “The Requirement of Organizations to Take Measures to Prevent Corruption” and provides that organizations are required to develop and implement measures to prevent corruption and states that such measures may include the following:

(1) designating departments and officers responsible for preventing bribery and related offenses;

(2) developing mechanisms for cooperation with law enforcement authorities;

(3) developing and implementing standards and procedures designed to ensure ethical business conduct;

(4) adopting a code of ethics and professional conduct for all employees;

(5) establishing means for identifying, preventing and resolving conflicts of interest; (6) preventing the creation and use of false and altered documents.

Continue Reading

Coordinated guidance from DC and London?

It was an odd event a few weeks ago when the U.K.’s Serious Fraud Office removed some Bribery Act guidance from its website without explanation.

The deleted guidance dealt with self reporting, corporate hospitality, and facilitating payments.… Continue Reading

U.K. anti-corruption enforcement threatened by budget cuts

After the fanfare of the U.K.’s Bribery Act 2010, which was predicted to bring about a significant upswing in national and global anti-corruption enforcement, the Government has proceeded to cut the budget of the Serious Fraud Office (SFO), the main enforcement agency, from £50 million in 2008/9 to below £30 million for 2013/14.… Continue Reading

From France, the enforcement news isn’t all bad

Antique engraving of Palais de Justice, Paris, France. Published in Systematische Bilder-Gallerie, Karlsruhe und Freiburg (1839). Courtesy of iStockThe extra-territorial reach of the FCPA and its impact are perhaps no better evidenced than by the colossal fines paid by Siemens in 2008.… Continue Reading

New Proposal For FCPA ‘Adequate Procedures’ Defense

Jon Jordan, a friend of the FCPA Blog, has just published a new article in the Stanford Journal of Law, Business & Finance.

It discusses the adequate procedures defense under the UK Bribery Act and explores suggestions for a similar kind of compliance procedures defense under the FCPA. … Continue Reading