February 20, 2018
February 01, 2018
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.
January 26, 2018
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.
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.
March 07, 2017 Third Party
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.
November 07, 2016 DOJ, FCPA
September 07, 2016 ABAC, ISO
June 07, 2016 ABAC, Whistleblower