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FCPA Blog Daily News

Entries in conflicts of interest (12)


When ‘conflicts of interests’ are good

In our Western corporate culture, we're conditioned to recoil at the idea of conflicts of interests. Conflicts of interest are bad, avoiding them is good, and there is no gray area in between. But is that always true?

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ICC publishes new guidelines on conflicts of interest in enterprises

Conflicts of interest may not be illegal per se. But they may lead to corruption, for example when someone uses their official authority to benefit themselves , a relative or friend. Therefore, preventing conflicts of interest can also prevent corrupt practices that can impair the organization.

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Joanna Ng: Using data to detect conflicts of interest and the harm they cause

Not all conflicts of interests lead to illegal conduct. But undisclosed connections between third-party suppliers and employees are a gateway to corruption and fraud. The best way to uncover conflicts of interests and harm flowing from them is through data.

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Annals of bad ideas: CEO of Hong Kong brokerage adds compliance officer role

KVB Kunlun Financial Group in Hong Kong announced that its current CEO will assume the additional role of compliance officer.

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After Gov. McDonnell (Part Three, concl.): How to fix Virginia's ethics laws 

Effective ethics laws, in Virginia and elsewhere, depend on enforcement through prosecution, independent ethics review boards, ethics training, and transparency and openness in government. In other words, Virginia will have to do more than change a few gift laws currently under review.

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After Gov. McDonnell (Part Two): Virginia's toothless conflict of interest laws

The State Integrity Project found that Virginia's ethics laws are among the least effective of the states for deterring corruption. The analysis cited Virginia’s weak conflict of interest laws, and found that those laws essentially have no bite.

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FINRA releases 2014 regulatory and exam priorities 

On Thursday, the Financial Industry Regulatory Authority (FINRA) released its 2014 Regulatory and Examination Priorities letter to help firms review and enhance their compliance programs. FINRA emphasized that it will be examining for strong controls and compliance efforts in the areas covered in the letter, as they were deemed to pose significant risk to investors and the integrity of the market as a whole.

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How do compliance officers vote with their feet?

When a compliance officer needs to vote with his feet, the key ingredients to look for at the next job are, among other things, a chief compliance officer who reports to an independent board, and incentives or bonus pay for outstanding work.

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The real code of conduct nobody mentions

We've been talking about codes of conduct for compliance officers. But let's face it. At too many companies, the true code is simple: Please Your Boss. The conflict resolution principle is Go Along to Get Along. In practice, at these companies compliance is subservient to the power and prerogatives of top management.

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Anti-Corruption (Back-to-School) Resource List

It's that time of year again. Across the country, law students are thinking about paper topics for seminar courses and journal notes. Like last year, I am posting a list of resources that I provide to students every fall in the Anti-Corruption seminar that I co-teach with my colleague, Professor Chris Yukins.

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New Russia law goes beyond FCPA, Bribery Act

A new Russian law, which went into effect on January 1, 2013, affirmatively requires companies to establish compliance programs.

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Halliburton continues multiple internal investigations

Oil field services giant Halliburton said this week its internal investigations into potential FCPA and conflict violations in Angola and Iraq are continuing, and the company is reporting all results to the DOJ and SEC.

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