It’s easy to get caught up in the dogma of how compliance programs have historically been managed.
Entries in Due Diligence (56)
Illegal logging is a $10 billion business, according to Interpol, and is falling into the clutches of organized crime.
Last week, the DOJ and SEC issued their long-anticipated Resource Guide regarding the agencies’ FCPA enforcement. Over a year in the drafting, the 120-page Guide addresses, among other things, (1) the definition of a foreign official, (2) gifts and entertainment, and (3) the “hallmarks” of an effective corporate compliance program.
Last year the OECD issued a 65-page publication called 'Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
Michael Short of Ethics360 has written a new white paper called “The Role of Due Diligence in Anti-Corruption Compliance: How Much Is Enough?”
Tom Fox with a great summary of the biggest FCPA stories from the first half of 2012.
The DOJ's two-count criminal information filed in the Eastern District of Virginia charged DS&S with conspiring to violate FCPA’s anti-bribery provisions and a substantive FCPA count.