The United States has long been regarded as the world’s leader in anti-bribery anti-corruption (ABAC) enforcement. Now China has joined the ranks of countries who have followed U.S. lead by creating their own ABAC laws.

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On November 29, 2017 Department of Justice (DOJ) Deputy Director Rod Rosenstein moved to formally enshrine the FCPA Pilot Program, begun under President Obama, by incorporating it in the U.S. Attorney’s Manual (USAM) at Title 9-47.120, now called the FCPA Corporate Enforcement Policy (“the Policy”).  Now that the policy has moved from an experiment to a fixture of the U.S. enforcement landscape, here’s what companies need to know to use it to their advantage.

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Compliance professionals in France have new guidance on how to evaluate and monitor third parties for compliance with Sapin II, the country’s overhauled anti-corruption law. Now comes the challenge of hammering those guidance principles into a sturdy structure that works for your own organization.

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Coming in 2018: More Transparency, More Third-Party Risk

December 27, 2017 Beneficial Ownership

In mid-December EU lawmakers adopted amendments to the region’s 4th AML Directive that will bring more transparency and enforcement to the corporate world. The intention is noble: to crack down on money-laundering, tax evasion, and other corporate corruption, as put on display by release of the Panama Papers in 2016. Compliance officers, however, will have fresh challenges for disclosure, third-party governance, and enforcement risk.

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Anti-Bribery Compliance Gaining Steam

September 21, 2017 ABAC, benchmarking, compliance week, survey

The results, revealed in a Sept. 13 webinar, emanate from a survey jointly conducted by Compliance Week and Steele Compliance Solutions that highlight the types of risk mitigation strategies companies are using today and how they are managing, monitoring, and assessing their third-party anti-bribery and anti-corruption (ABAC) programs over time.

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The unrelenting pace of change in today’s regulatory environment continues to generate a seemingly unending, and increasingly onerous, list of ABAC laws and regulations that companies must understand and comply with if they are to avoid attracting the attention of government watchdogs.

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What Investigators Want to Know About Your Program

March 01, 2017 DOJ guidance, FCPA, third-party compliance

Earlier this year, the Fraud Section of the Department of Justice’s (DOJ) Criminal Division surprised compliance officers with guidance on how regulators measure the effectiveness of third-party compliance programs. The release of the Evaluation Corporate Compliance Programs guidance aims to clear up confusion regarding what regulators look for when assessing corporate compliance programs during investigations.

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Assistant Attorney General Leslie R. Caldwell recently delivered a speech to The George Washington University Law School that touted her achievements as head of the Department of Justice Criminal Division.

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Rising Whistleblower Awards

June 07, 2016 ABAC, Whistleblower

In its continued and growing effort in cracking down on corporate corruption, the Securities and Exchange Commission (SEC) has credited whistleblowers as key to its success. And, if recent history is any indication, the agency has no plans of slowing down these efforts.

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