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FCPA and Bribery Act Hotlines: Staying Out of Hot Water with Other Jurisdictions
It is finally here. Today is the Opening Ceremony of the Games of the XXX Olympiad in London. The first Olympics I can remember watching were the 1964 Games in Tokyo. I was enthralled
Read More »Measuring Deterrence: How Big a Fine Will Deter Corporate Crime?
The Justice Department takes a lot of flack from the business community for settling civil and criminal cases with large fines and penalties. The recent GlaxoSmithKline settlement of $3 billion underscored an important
Read More »The Bribery Act: one year on
The UK Bribery Act 2010 came into force on July 1, 2011 and represents an attempt to replace an outdated anti-corruption regime that had attracted strong criticism from influential international bodies such as the
Read More »8 Questions Directors and Senior Management Should Ask About Their Company’s Anticorruption Compliance Efforts
In the wake of continuing press reports about the role of bribery in international commerce, many corporate directors and senior executives are asking for a fresh look at their company’s exposure to the risks
Read More »Three Perspectives on M&A FCPA Due Diligence
A general counsel of a private equity firm recently told me that it is helpful for him to consider FCPA compliance issues through the lenses of the various actors involved. In that spirit, FCPAméricas
Read More »New UK anti-bribery laws to impact SA firms
South African companies that have operations in the UK or the US - or are listed in these territories - that fail to comply with anti-corruption legislation could be on the receiving end of
Read More »Anti-Corruption Programs: Think Strategically
In the face of ever more aggressive enforcement of anti-corruption and wider anti-financial crime legislation, the management teams of even the most well-prepared multinational companies are asking themselves not “if,” but “when” they will
Read More »Facilitation Payments: Are They Legal Bribery?
One of the more frequent questions I hear during webinars and at seminars centers on the issue of facilitation payments. Often the question is “Do you really believe that companies can comply with
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