Posts Tagged ‘FCPA’
Fresh Help on Bribery Risk Indicators
Good news for anti-corruption enthusiasts! Five law enforcement agencies around the world have published fresh guidance on indicators of foreign bribery, to help you focus your anti-corruption risk assessments and be sure that your compliance program has the right structure and resources to tackle the threat. The guidance was released just before Christmas by the…
Read MoreWait, Does Bribery Pay Off After All?
Fresh research suggests that the Trump Administration’s freeze on FCPA enforcement earlier this year led to a jump in the share price of corruption-prone businesses — which, in turn, raises some unsettling questions about how to make a culture of ethics and compliance truly stick in an era of diminished enforcement. The research comes from…
Read MoreMore Muddled Messages From DOJ
An update on anti-corruption enforcement in the United States: one week after the deputy attorney general lectured compliance officers that no, really, the Trump 2.0 Administration is serious about enforcement and not just targeting foreign business rivals, prosecutors have dropped two corruption cases related to FIFA while preparing to hammer Chinese telecom giant ZTE Corp.…
Read MoreCompliance Amid ‘Aggravating Circumstances’
Today let’s return to some issues raised during last week’s ACI conference about FCPA enforcement. Speakers offered a few examples of when the Justice Department might still press for vigorous prosecution (rather than a straightforward declination), and compliance officers have much to consider here. For starters, let’s remember that the Justice Department announced new, more…
Read MoreJustice Dept. Talks FCPA Again
The Justice Department is launching a charm offensive with the FCPA compliance community this week, telling compliance professionals at a conference in Washington today that enforcement is returning to “more of the traditional cadence” and we can expect to see more enforcement actions next year. Whether anyone believes those words is another matter, and we’ll…
Read MoreOn Corruption Risk and Lucrative Deals
Compliance professionals have one more issue to consider from that FCPA enforcement action last month against Millicom for corruption in Guatemala. Let’s look at what the case can tell us about the tug of war between lucrative business potential and corruption risk. This has been on my mind since the Justice Department reached the settlement…
Read MoreU.K. SFO Guidance on Compliance Programs!
Good news for compliance officers looking for an excuse to avoid awkward family conversation at Thanksgiving: the U.K. Serious Fraud Office just issued new guidance on when and how the agency will evaluate corporate compliance programs. The SFO issued the guidance on Wednesday. It outlines six scenarios where SFO prosecutors might decide they need to…
Read MoreCorporate Compliance and ‘Cartel Risk’
Last week I moderated a webinar on Latin American drug cartels, and where “cartel risk” is or isn’t similar to the corruption risks that compliance teams have worried about for years. Perfect timing! That same week, the Justice Department settled an FCPA case where drug trafficking was one element of the story. Let’s review the…
Read MoreMillicom FCPA Settlement, Part II
Today we return to that FCPA enforcement action last week against Millicom, which paid $118.2 million to settle criminal charges of bribery and corruption in Guatemala in the 2010s. The filings in the case have been unsealed, and they raise a few points worth compliance officers’ attention. First, a quick recap for those who missed…
Read MoreFCPA Enforcement Is Happening!
Who says FCPA enforcement has flat-lined under the Trump Administration? Well, pretty much everyone, including the Administration itself — but apparently not! Prosecutors settled FCPA charges on Monday with Millicom Cellular, which is paying $118.2 million and entering a two-year deferred-prosecution agreement for corruption payments in Guatemala. The news comes from Millicom itself, which issued…
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