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Entries in Due Diligence (101)

Friday
Sep302016

Nicolas Tollet on the new French anti-corruption law: Shall we be scared of France now?

For more than a year, France has been working on improving its legislation to enact a new anti-corruption law in order to reach the same standards as the FCPA, the UK Bribery Act or the Brazilian Clean Company Act.

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Wednesday
Sep212016

Dan Adamson: Sorry, but a Google search isn’t due diligence

I cringe when compliance teams rely solely on Google to investigate and make decisions.

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Thursday
Sep012016

Here's some open source due diligence on Och Ziff's Africa agent

After reviewing several articles including the recent FCPA Blog post, "Alleged Och Ziff Africa 'fixer' arrested for FCPA offenses," my focus immediately shifted to due diligence procedures. Specifically, I thought about the risk profile of Samuel Mebiame. 

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Thursday
Aug252016

Practice Note: How to handle real estate compliance risks

In the prior post, we talked about anti-corruption enforcement actions and investigations involving real estate. Now let's look at real estate-related compliance.

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Friday
Aug122016

Nicole Rose: If compliance were an Olympic sport, what would it be?

The Olympics are on and everywhere I go people are excited and inspired. I personally feel that just by watching, I'm part of something great. 

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Wednesday
Jul272016

CIPE: The biggest anti-corruption organization you’ve never heard of

A post this week by Frank Brown talked about spreading compliance to supply chains in high-risk jurisdictions. It's a challenge without easy answers.

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Monday
Jul252016

Frank Brown: A plan for integrating local partners into the global supply chain

Local firms in emerging markets are often highly attractive to multinationals looking for new suppliers and partners. Those local firms, many of them mid-sized, see joining a global value chain as a key step for survival.

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Wednesday
Jul132016

What does ISO 37001 say about due diligence?

ISO 37001-- a new standard for anti-bribery management systems -- slated to be published in late 2016, is expected to be more detailed and internationally recognized than similar guidance published to date.

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Tuesday
May312016

Hiring foreign officials: How do you justify it?

One of the threshold questions for a company considering the engagement of a government official is whether the engagement is needed for legitimate purposes. If the company cannot articulate an adequate and appropriate business justification, there is a risk that the engagement may be sought or undertaken for a corrupt purpose.

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Wednesday
May112016

Alison Taylor: We can use stakeholder trust to measure integrity risk

The last five years have seen a dramatic shift in the transparency environment, in a trend that began with Wikileaks launching the Arab Spring, and which is now reaching fruition in the vast data leaks from Luxembourg, Unaoil and Panama. Companies can no longer reliably distribute information as they choose, or maintain control over its interpretation.

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Tuesday
May102016

Scott Shaffer: When things go wrong, your due diligence was never enough

The Unaoil scandal has again brought FCPA due diligence to the forefront. Specifically, the question asked of compliance officers is, “How much due diligence is enough?” 

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Monday
May092016

Shruti Shah on the U.S. response to the Panama Papers: A step in the right direction but more action is needed

Secretary of State John Kerry will attend the London Anti-Corruption Summit on May 12The massive leak dubbed the Panama Papers has given the UK Anti-Corruption Summit on May 12 an unexpected boost. Those coming to the summit, now including the U.S., are lining up to make announcements about the steps they are taking to tackle corruption and specifically financial secrecy.

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