Blogs

As most of the readers of this blog will recall, I recently discussed the substance of Opinion Release 11-01 and had some additional comments regarding the relative ease by which a lawyer or compliance office should have been able to research the question posed. read more

In an article in Monday’s New York Times (NYT) entitled “At I.M.F, a Strict Ethics Code Doesn’t Apply to Top Officials”, Graham Bowley reported that there are two separate sets of ethics guidelines; one for the 2400 “rank-and-file staff and another for the 24 elite executive directors who oversee the powerful organization. read more

New Zealand is generally recognized as having some of the lowest instances of corruption across the globe, at least that is the perception. read more

Ed. Note-today we have a guest post from Michael Potorti, CPA of MP Audit Executive Management is increasingly turning to their Internal Audit Department to assess the risk of FCPA and UK Bribery Act non-compliance on their business and develop ways to mitigate those risks. read more

One of the panels I attended this week at Compliance Week 2011 was co-chaired by Andy Hinton, Chief Compliance Office (CCO) of Google, and Leonard Shen, CCO of PayPal. read more

In a session at Compliance Week 2011 entitled, “Implementing a Compliance Program in a Global Business Using a Holistic GRC Model”, the speakers, John Farrell and James Littley, both of KPMG and Robert Brewer, Chief Compliance Officer of Office Depot presented a model to consider for a Bribery Act compliance system. read more

In an article entitled “Learning to Work with Green Activists” published in this month’s Harvard Business Review, Chairman, President and Chief Executive Officer (CEO) of Duke Energy, James E. read more

There are several recent examples where companies, bought both businesses and there pre-existing violations of the Foreign Corrupt Practices Act (FCPA), in large part because the acquiring companies failed to perform sufficient FCPA due diligence it the overall pre-acquisition due diligence. read more

As we have noted, the key to any testing, whether in the form of an audit or assessment, of your Bribery Act or Foreign Corrupt Practices Act (FCPA) compliance program is not to be afraid of the results. read more

One of the areas of risk which is traditionally assessed is that of geography or country risk. The UK Bribery Act Guidance defines country risk as: Country risk: this is evidenced by perceived high levels of corruption, an absence of effectively implemented anti-bribery legislation and a failure of the foreign government, media, local business community and [. read more