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Harry Cassin Publisher and Editor

Andy Spalding Senior Editor

Jessica Tillipman Senior Editor

Richard L. Cassin Editor at Large

Elizabeth K. Spahn Editor Emeritus 

Cody Worthington Contributing Editor

Julie DiMauro Contributing Editor

Thomas Fox Contributing Editor

Marc Alain Bohn Contributing Editor

Bill Waite Contributing Editor

Shruti J. Shah Contributing Editor

Russell A. Stamets Contributing Editor

Richard Bistrong Contributing Editor 

Eric Carlson Contributing Editor

Bill Steinman Contributing Editor

Aarti Maharaj Contributing Editor


FCPA Blog Daily News

Entries in internal controls (26)

Tuesday
Jan152019

And the big compliance story for 2019 is . . . . 

Nearly every corporate anti-bribery violation reveals problems with internal controls.

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Wednesday
Dec192018

Ex-Panasonic officers settle SEC charges after $280 million FCPA resolution

Two former senior executives of U.S.-based Panasonic Avionics Corporation settled SEC charges Tuesday related to FCPA offenses that Panasonic Corporation and the U.S. aviation unit settled earlier this year.

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Tuesday
Mar062018

Risk Alert: Are bribes lurking on the balance sheet?

When choosing transactions to test as part of anti-bribery assessments, the usual suspects include expense accounts like consulting, marketing, promotions, commissions, or miscellaneous. Other expense accounts are selected based on the nature of the company’s business, risk factors or descriptions of the account.

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Wednesday
Oct252017

David McLaughlin: How AI can nail a bribe paying scrap metal dealer

Last year 27 companies paid nearly $2.5 billion to resolve FCPA-related offenses. So far this year, 9 companies have paid more than $1.2 billion for FCPA-related settlements. Yet despite these staggering outcomes, existing tools deployed today by corporations are not capable of effectively mitigating FCPA risk.

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Monday
Jan302017

How perverse incentives cause companies to abandon controls

In the prior post, we talked about reasonable goal setting that can turn into perverse incentives, leading to compliance and reputational disasters like Wells Fargo. In this post, we look at whether companies can contain the excesses of their incentive programs with controls.

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Friday
Aug122016

Key Energy pays $5 million to settle FCPA offenses in Mexico

Houston-based Key Energy Services, Inc. agreed to disgorge $5 million to settle Foreign Corrupt Practices Act offenses caused by bribes from its Mexican subsidiary to an employee at state-owned Pemex.

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Monday
Feb012016

SAP settles Panama bribes case with SEC for $3.9 million

The Securities and Exchange Commission said Monday that software maker SAP SE agreed to pay nearly $3.9 million to settle charges that it violated the Foreign Corrupt Practices Act by paying bribes to win business in Panama.

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Thursday
Aug062015

Practice note: BHP Billiton and expanding enforcement of FCPA internal controls provisions

The SEC took a seemingly aggressive stance in the BHP Billiton case, penalizing the Australian company $25 million for FCPA offenses because it sponsored foreign officials to attend the 2008 Summer Olympics in Beijing.

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Monday
Mar092015

Are FCPA books and records and internal controls defenses becoming obsolete?

Many of us scratched our head in 2010 when the Oracle FCPA enforcement action came out. We didn't understand how a company could be prosecuted, even civilly by the SEC for internal controls or book and records violations, without evidence that bribes had been paid. But after the past few months, I think Oracle was a precursor to a strict liability standard that's coming to FCPA enforcement.

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Wednesday
Feb182015

After Bruker: How much compliance is enough?

In the world of anti-corruption internal controls, there is no “one-size-fits-all” model. Ideally, design and implementation of such controls should be thoughtful, rigorous and based on a robust and re-performable corruption risk assessment. 

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Wednesday
Jan282015

International Franchising and the FCPA (Part Three): Best Practices

This post continues from Part One: Vicarious Liability and Part Two: A Flock of Foreign Officials.

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Monday
Dec222014

Alstom pays $772 million for FCPA settlement, SFO brings new charges

Alstom Chief Executive Officer Patrick Kron (Image courtesy of Alstom)Paris-based Alstom pleaded guilty Monday to bribing officials in Indonesia, Saudi Arabia, Egypt, and the Bahamas. It will pay $772 million in criminal penalties to settle the charges, the DOJ said.

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