Oracle Hit 2nd Time on FCPA Violations

Oracle

The Securities and Exchange Commission has sanctioned Oracle for violations of the FCPA, the software giant’s second such incident in 10 years and one that provides a chance for the rest of us to talk about recidivist FCPA offenders.  What happened? In one sense, the usual. Throughout the 2010s, Oracle subsidiaries in India, Turkey, and…

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A Compliance Experiment in GIFs

GIFs

Any compliance professional worth his or her salt knows that clever communication about ethics and compliance policies is crucial to winning over employees’ enthusiasm. So when a compliance officer (who shall remain anonymous) shared with me a prototype “anti-bribery compliance through GIFs” — well, that was too good not to publish.  Therefore we humbly submit…

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‘Reasonable Design’ and CCO Certifications

reasonable

Today I want to revisit the Justice Department’s plans to have chief compliance officers certify the effectiveness of their compliance programs, to unpack a question that’s been bothering me. When the department says it wants certification that your program is reasonably designed to prevent future violations, what does “reasonable” actually mean?  Readers of Radical Compliance…

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Lessons From Glencore Settlement

Glencore

Earlier this week Swiss commodities trading giant Glencore gave the compliance community a doozy of a corporate corruption settlement, agreeing to pay more than $1 billion to regulators around the world for bribery and market manipulation that lasted more than a decade. I’ve been sifting through the settlement documents since then and we have several…

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Some Polite Words on Testing

fcpa

Gather round, corporate compliance professionals. We have another speech from a high-ranking Justice Department official about how compliance programs should work, and as usual these days, the speech is full of clues that are well worth your time and attention. The speech came from Kenneth Polite, assistant attorney general for the Criminal Division, who spoke…

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FCPA Reminders From Stericycle

Stericycle, the global medical waste giant, has agreed to settle FCPA charges against the company for widespread bribery in Latin America, giving the rest of us another case with lessons about the risks of rapid international growth and poor corporate culture. The settlement was announced Wednesday. Stericycle will pay $84 million in penalties to the…

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KT Pays $6.3M to End FCPA Case

KT

Compliance professionals have quite the FCPA case to consider this week, courtesy of the Securities and Exchange Commission hitting Korea’s largest telecommunications carrier with $6.3 million in penalties and disgorgement for all manner of corrupt practices in the 2010s. The company, KT Corp., has a long history of corruption. KT agreed to settle the SEC…

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Study: CCOs Put DOJ Guidance to Use

justice

A study released this week finds that most chief compliance officers are aware of, and appreciate, the guidance on effective corporate compliance programs that the Justice Department has churned out in recent years — although CCOs would like more examples from the department of decisions not to prosecute a company based on its compliance efforts. …

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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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