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Entries in Due Diligence (98)

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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Wednesday
Apr132016

Bill Waite on Unaoil: Certification versus Investigation

I have not had sight of the TRACE reports into Unaoil but no doubt in time they will become public. I am confident that TRACE did what it was contracted to do and exercised skill and care in so doing. It is a professional organization.

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Tuesday
Apr122016

Alexandra Wrage on Unaoil: The importance -- and limitations -- of due diligence

The Unaoil story first published by The Age and Huffington Post on March 30, and supplemented yesterday with another chapter, has it all. There are code names, huge dollar amounts and intrigue. 

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Monday
Apr112016

The Unaoil story (remember that one?) has already raised the bar for reacting to red flags

The Huffington Post/Fairfax Media’s report of bribery at Unaoil is another cautionary tale on how entire industries can find themselves under investigation for use of the same intermediary.

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