Diving Into Glencore Compliance Report

Glencore

Commodities trading giant Glencore published an in-depth look at its ethics and compliance function this week, part of the company’s penance for a corporate corruption scandal it settled in 2022. Anyone wanting a glimpse into how global businesses might structure their compliance operations, especially when recovering from a misconduct scandal, look no further.  As you…

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So Much Anti-Corruption Compliance News!

corruption

We’ve seen a flurry of news in anti-corruption compliance this week — and while not all of it is bad, nor does it mean an end to corporate ethics and compliance, lots of it is rather disheartening. Let’s take a look and try to make sense of things. First is news from the Securities and…

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Europe Forms Anti-Corruption Enforcement Team

corruption

Stay on your toes, compliance officers! Britain, France, and Switzerland have announced the launch of a new anti-corruption taskforce, meant to keep up the pressure against corporate bribery and corruption even as the Trump Administration retreats from it. The leaders of the U.K. Serious Fraud Office, the Parquet National Financier in France, and the Office…

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Australia’s Adequate Procedures Guidance

Australia

Today we have a guest column from Mary Shirley, chief compliance officer at ScionHealth.  Earlier this year Australia passed new anti-corruption legislation known as the Crimes Legislation Amendment (Combating Foreign Bribery), and in August the government released voluntary guidance to help corporations understand the “adequate procedures” — that is, the elements of an effective compliance…

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Corruption Is Still Corruption, Folks

corruption

Yes, the Supreme Court reached a preposterous conclusion last Friday in Snyder v. United States, when the conservative majority ruled that a “gratuity” that’s plainly part of a corrupt bargain is not a crime under federal anti-corruption law. Anxious corporate compliance professionals, however, should begin by asking a crucial question: Who cares?  Seriously — how…

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FEPA: A Huge Step on Foreign Bribery

corruption

We have a Christmas season surprise for all you anti-corruption enthusiasts out there! Washington has just passed the Foreign Extortion Prevention Act, a law that makes it a crime for foreign government officials to demand or accept a bribe from a U.S. company. FEPA, as the legislation will now be forever abbreviated, was folded into…

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2022 Corruption Perceptions Index

corruption

Transparency International has released its annual ranking of corruption levels in countries around the world, with Scandinavia and New Zealand leading as usual while the United States place a rather underwhelming 24th. TI publishes its Corruption Perceptions Index at the start of every year, and the index has become a standard reference work that compliance…

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A View on Corruption From Ukraine

Ukraine

Earlier this week I recorded our usual Compliance Into the Weeds podcast with my friend and colleague Tom Fox, plus a special guest: Timur Khasanov-Batirov, a compliance officer and anti-corruption officer in Ukraine. Given the importance of the war in Ukraine, our conversation with Khasanov-Batirov deserves its own written post as well. Several points are…

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Biden Admin Unveils Anti-Corruption Strategy

anti-corruption

The Biden Administration has released its strategy on countering corruption around the world, with lots of talk about cross-border collaboration, data collection, and tougher U.S. enforcement; but relatively little about new legislation that might add fresh burdens to anti-corruption compliance programs.  The White House released the strategy document, 38 pages long, on Monday morning. It…

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China’s New Anti-Corruption Maneuver

anti-corruption

It seems that China is revising its anti-corruption rules to give it a stronger hand in prosecuting overseas corporations that bribe government officials, in case you need yet another headache in your compliance officer life.  We don’t know the exact details of the new rules or even have a copy of them available to the…

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