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Richard L. Cassin Publisher and Editor

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Jessica Tillipman Senior Editor

Elizabeth K. Spahn Editor Emeritus

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Thomas Fox Contributing Editor

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Bill Waite Contributing Editor

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FCPA Blog Daily News

Entries in Due Diligence (131)

Wednesday
Apr182018

Pia Vining on due diligence: Automation is useful but human judgment is indispensable

Brad Gates (“Is third party due diligence a commodity?”) and Scott Shaffer (“Due diligence will always be a human skill”) make interesting points and both are right.  While automation can be useful, human judgment is indispensable. 

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Friday
Apr132018

John Arvanitis: Complying with FinCEN's new customer due diligence rules

Kroll's John ArvanitisOn May 11, FinCEN's Final Rule regarding customer due diligence will be in force. That means covered financial institutions will have to make sure their due diligence programs are in line with FinCEN’s guidance on core elements of a customer due diligence program.

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Monday
Apr092018

Spinelli and Murtha: FCPA due diligence in healthcare M&A

At a conference recently, Sandra Moser, the acting Chief of the Fraud Section of the Department of Justice (DOJ) announced that the prosecutors from the agencies' Foreign Corrupt Practices Act (FCPA) Unit would be collaborating with the Corporate Strike Force of DOJ's Health Care Fraud Unit to investigate healthcare corruption here in the United States and abroad.

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Monday
Dec112017

UK Regulator: Smart machines alone can't defeat money laundering

Rob Gruppetta, Head of the Financial Crime Dept. at the FCAArtificial intelligence will always be a "work in progress" in fighting money laundering and won't entirely replace humans and their intuition, a top UK regulator said.

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Monday
Dec112017

Jerry Hansen: What about due diligence for domestic M&A?

Anti-bribery and corruption due diligence should be conducted on cross-border transactions. The prospect of successor liability alone makes performing such due diligence a requirement for corporate acquirers answering to boards and shareholders, and private equity funds answering to investors.

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Thursday
Nov162017

Emma Hodges: Blockchain is where anonymity meets transparency

While digital currencies -- Bitcoin or one of its many variations -- continue to make inroads into payments markets, many companies, financial institutions, government bodies and others are still playing catch-up. 

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Monday
Nov132017

Robert Clark: Will the EU data protection rule block due diligence?

Companies minimize the risk of corruption by adequately vetting their prospective representatives -- typically by reviewing information about the financial interests and relevant connections of the intermediaries’ owners and key personnel, and screening those individuals for reputational and criminal-history issues.

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Tuesday
Oct102017

Rupert Evill on business partner risks: Stress-test your business

A key challenge for most companies is finding qualified business partners with an understanding and acceptance of ethics and compliance best practice. The challenge is most acute in markets where the state dominates commerce or with stringent local content requirements.

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Monday
Oct092017

John Arvanitis: A compliance plan for FinCEN’s new customer due diligence rule

The Financial Crimes Enforcement Network's Final Rule regarding customer due diligence will soon be in force. With implementation required by May 11, 2018, covered financial institutions must ensure their due diligence programs are in line with FinCEN’s guidance on core elements of a customer due diligence program.

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Wednesday
Oct042017

Karen E. Gray: ISO 37001 certification can help companies prepare for DOJ industry sweeps

After news broke that the U.S. Department of Justice was investigating Uber’s potential violations of the Foreign Corrupt Practices in late August, the National Law Review wrote, “In our experience, once DOJ begins learning about a particular industry in such an investigation, the investigation will expand to other players within the industry. It’s called an ‘industry sweep,’ and it’s a thing.”

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Friday
Sep082017

Enforcement agencies to world: New technologies raise bar for due diligence

The growing complexity of third-party relationships, and the immediate regulatory and reputational risks of those third parties has procurement teams, compliance officers and legal departments working to figure out the best way to proceed.

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Wednesday
Sep062017

Compliance Alert: Another reason life is hard for defense contractors

There are no two ways about it. Indirect offset transactions are burdensome. 

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