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Entries in Due Diligence (71)

Wednesday
Jun242015

Joseph Spinelli: Risk assessments should be functional and geographical

In our 2015 ABC Report, Kroll asked respondents to identify what they considered to be the type of corrupt behavior the chief compliance officer must guard against.

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Tuesday
Jun232015

To manage compliance risk, first find it

Corrupt payments are made to achieve important objectives -- important enough to risk possible loss of reputation and criminal prosecution. The most common objectives are winning business, maintaining business, and executing transactions faster.

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Tuesday
Jun232015

Joseph Spinelli: Risk assessment best practices

The DOJ and SEC expect diverse functional areas of organizations to participate in compliance risk assessments. Among them are compliance, legal, internal audit, procurement, and finance. Human resources, marketing, and public relations also usually have a role.

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Monday
Jun012015

Survey: Enforcement drives compliance, and whistleblowers rise

AlixPartners recently conducted its annual anticorruption survey which looked at the impact corruption has on corporate and economic growth. In particular, we explored the ways companies are identifying corruption risk and the steps they're taking to deal with the risks.

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Wednesday
Apr082015

New anti-corruption regulation reaffirms Brazil’s focus on prevention

Sao Paulo, Brazil - March 15, 2015: Protesters marching on Paulista Avenue against government corruption.On March 18, Brazil’s president Dilma Rousseff issued a decree that clarifies and facilitates enforcement of the country’s main tool against corporate bribery, the 2013 Clean Companies Act (“CCA”). This regulation was highly anticipated and came at a sensitive time, just a few days after massive protests against the government, and in the middle of a snowballing scandal at Petrobras that led to the first (or first high-profile) CCA enforcement actions.

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Thursday
Mar122015

Groups urge KYC rules for real estate to fight money laundering

Shruti Shah of TI-USA (Image courtesy of C-Span)Transparency International-USA sent a letter to the U.S. Treasury Department Tuesday, endorsed by 17 civil society groups, asking for due diligence requirements for professionals in the real estate sector.

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Tuesday
Feb102015

Compliance Alert: Five risks for Fashion Week 2015

Image courtesy of Mercedes-Benz Fashion WeekFashion Week 2015 begins on February 12 in New York. Compliance will certainly not be on the agenda and the fashion industry has never attracted the kind of regulatory attention “enjoyed” by industries that rely heavily on public sector sales. But that doesn't mean that the industry is free of corruption risks and immune from potential FCPA enforcement actions.

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Wednesday
Feb042015

What's new in OFAC compliance

Enforcement actions against sanctions violations by the Office of Foreign Assets Control (OFAC) have risen dramatically. Sanction offenses can carry civil and criminal liabilities, with a single transaction potentially resulting in multiple violations.

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Wednesday
Jan282015

International Franchising and the FCPA (Part Three): Best Practices

This post continues from Part One: Vicarious Liability and Part Two: A Flock of Foreign Officials.

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Thursday
Jan222015

Three steps to better compliance in 2015

It's the time of year for compliance planning and scheduling. Here are three steps to consider to assure that your organization is meeting its FCPA compliance obligations during 2015.

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