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FCPA Blog Daily News

Entries in Red Flags (37)

Monday
Aug282017

Bethany Hipp: How can compliance officers protect themselves from harm?

Recent enforcement actions suggest that regulators, both in the United States and the UK, are targeting compliance officers.  

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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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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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Thursday
Mar312016

SFO: How should companies handle attorney-client privilege during investigations?

Alun Milford, SFO General Counsel (image courtesy fo the SFO)In a speech this week to compliance professionals at the European Compliance and Ethics Institute in Prague, the general counsel of the UK Serious Fraud Office talked about attorney-client privilege in connection with SFO corruption investigations.

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Monday
Nov302015

Barclays fined $108 million for kowtowing to rich PEPs

The UK Financial Conduct Authority fined Barclays Bank £72 million ($108 million) Thursday for rushing to serve rich politically exposed persons and keeping their deal secret.

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Tuesday
Nov032015

Overreacting to risk can ruin a compliance program

In-house counsel, compliance officers and the external counsel who support them are trained to be risk averse when it comes to anti-corruption and other types of compliance, and with good reason.

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Tuesday
May192015

Inside view: What do corrupt organizations look like?

The concept of corporate culture -- generally defined as "the way we do things around here" -- isn't a rigid paper process. It's hard to measure, which explains why corporate culture has been largely neglected by regulators and the anti-corruption-consulting industry.

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Tuesday
Jan132015

Je Suis Charlie: Compliance protects us all

The global demonstrations that gathered under the banner “Je Suis Charlie” had special meaning for us at the University of Miami as we offered the second iteration of our undergraduate Compliance Boot Camp.

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Tuesday
Jul152014

Walmart in Delaware: A tale of red flags ignored

At oral argument Thursday in the Delaware Supreme Court, where Walmart is appealing a lower court order to produce internal FCPA investigation files to shareholders, one remarkable exchange indicated that the idea of revising the Caremark standards, which I talked about in my prior post, was squarely on the minds of the justices.

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Monday
Apr282014

FinCEN penalizes money services business for ineffective AML prgram

The Financial Crimes Enforcement Network penalized a money services business and its owner for anti-money laundering program failures and violations of the reporting and recordkeeping requirements of the Bank Secrecy Act.

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Wednesday
Mar052014

Conflict minerals: Due diligence, disclosure lessons for compliance (Part 1)

The four conflict minerals -- tantalum, tin, tungsten and goldThis post is the first in a series of three on the topic of conflict minerals. The first examines the origins of the reporting requirement, and the following two will explore what constitutes sufficient due diligence when conducting an investigation of a company and its supply chain.

Section 1502 of the Dodd-Frank Act of 2010 requires companies using conflict minerals in their products to disclose the source of such minerals, hoping to dissuade companies from continuing to engage in trade that supports these human rights abuses.

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Wednesday
Feb122014

Surprise! Compliance has growing role in business decisions

A new survey of general counsels and compliance officers found that 30% of companies in North America, Europe, and Asia stopped doing business with a partner because of corruption risks.

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