When it was signed into law in 1977, the Foreign Corrupt Practices Act was very much an American approach to a global problem: how corruption in general and bribery in particular was skewing international business.
Entries in Hui Chen (20)
CCOs know that accountability and discipline are difficult and perilous areas to embed in their programs for a number of reasons.
Dear FCPA Blog,
I am writing today because I recently learned about the DOJ’s new “Evaluation of Corporate Compliance Programs,” which they released on February 8, 2017 without apparent fanfare.
How will President Trump and the new administration view compliance officers and their work? Are compliance officers friend or foe?
Employees at Wells Fargo opened about two million deposit and credit card accounts that customers didn't authorize. Why? To earn incentive compensation for new accounts.
Major conferences like Compliance Week 2016 are the perfect venue for witnessing the continuing development of the dynamic and fast-evolving compliance profession.
“I have to believe my compliance work is relevant to this tragedy. I have to believe the mission of compliance can help. If you stay in this transformative work in progress called Compliance 2.0, you have a sense of mission that makes it worth it. Compliance officers can address that moral gap of 'lawful but awful' conduct. They are empowered under Compliance 2.0 to debate with management and the Board the hard questions, starting with: 'It’s legally permitted but is it who we are?'"
In my family we knew two of the young people murdered at the Pulse Club in Orlando in the worst mass shooting in American history, with 49 killed and 53 wounded.
The DOJ’s FCPA Guidance and Enforcement Plan places significant emphasis on organizational culture. The section describing “an effective compliance and ethics program” includes “whether the company has established a culture of compliance, including an awareness among employees that any criminal conduct, including the conduct underlying the investigation, will not be tolerated.”