International Coordination and Cooperation in Corruption Cases

Global anti-corruption enforcement is fast becoming a complicated affair. No longer can companies just… [continue]

International Coordination and Cooperation in Corruption Cases International Coordination and Cooperation in Corruption Cases

More Than Due Diligence: Never-Ending Due Diligence

Due diligence of third parties can drive you crazy. You know you are in trouble when you start babbling… [continue]

More Than Due Diligence: Never-Ending Due Diligence More Than Due Diligence: Never-Ending Due Diligence

Where the Action Is: The SCCE Annual Meeting

If anyone wants proof that the compliance profession is on the rise, if anyone still doubts that the… [continue]

Where the Action Is: The SCCE Annual Meeting Where the Action Is: The SCCE Annual Meeting

Customer Due Diligence and Beneficial Ownership

Compliance officers face lots of challenges when conducting third-party due diligence. One issue that… [continue]

Customer Due Diligence and Beneficial Ownership Customer Due Diligence and Beneficial Ownership

Corporate Wrongdoing and Deterrence

The debate over corporate wrongdoing, punishment and deterrence continues.   Corporations are not people… [continue]

Corporate Wrongdoing and Deterrence Corporate Wrongdoing and Deterrence
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International Coordination and Cooperation in Corruption Cases

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Global anti-corruption enforcement is fast becoming a complicated affair. No longer can companies just focus on the FCPA, with momentary blips of concern for the UK Bribery Act. The OECD and other international organizations want to see aggressive enforcement around the globe, and they are doing a great job of … Continue Reading…

More Than Due Diligence: Never-Ending Due Diligence

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Due diligence of third parties can drive you crazy. You know you are in trouble when you start babbling to yourself and others about red flags, more red flags, and even more red flags. You can start thinking that the movie, “The Shining” was a documentary depicting your third-party due … Continue Reading…

Where the Action Is: The SCCE Annual Meeting

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If anyone wants proof that the compliance profession is on the rise, if anyone still doubts that the young professional of compliance is rapidly growing, all you have to do is attend an annual meeting of the Society of Corporate Compliance and Ethics (“SCCE”). I had the honor of attending … Continue Reading…

Customer Due Diligence and Beneficial Ownership

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Compliance officers face lots of challenges when conducting third-party due diligence. One issue that frequently arises is determining who exactly owns a potential agent or distributor. In many circumstance compliance officers have a difficult time peeling back the layers of legal ownership, examining related party ownership stakes and other complexities … Continue Reading…

Corporate Wrongdoing and Deterrence

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The debate over corporate wrongdoing, punishment and deterrence continues.   Corporations are not people but are entities that operate through collective behavior. It is interesting to consider whether individual punishment versus corporate entity punishment effectively deters corporate wrongdoing. After all, a company is only liable for individual conduct that is attributed … Continue Reading…

Joint Ventures and Compliance: Defining the Issues (Part I of III)

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One of the more challenging areas in the anti-corruption field is navigating joint venture risks.   Companies rely on joint venture partners for a variety of purposes – local partners know the geographic market, have a specific skill set that integrate well with the company’s operations, and offer a cost-effective means … Continue Reading…

Fraud and Bribery – They Go Hand in Hand

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Compliance officers need to dig into and understand a company’s internal controls. Many compliance officers tend to leave that issue to Internal Auditors – that is a big mistake. Compliance officers have to be multi-disciplinary experts, ranging from legal, to financial and business strategies. Frankly, in the corporate governance world, … Continue Reading…