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FCPA Blog Daily News

Entries in Red Flags (40)

Friday
May112018

Anne Fleur Goedegebuure: What can go wrong (and right) with third-party due diligence?

Working with third parties continues to be the single biggest corruption risk for business. Almost one in two enforcement actions concluded since the OECD Anti-Bribery Convention came into force in 1999 was the result of bribery through sales agents, intermediaries, distributors or brokers.

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Monday
Apr302018

McEachern and Pollitt: Use your existing data to power compliance

In the majority of bribery and corruption investigations -- from relatively simple matters to complex cross-border affairs -- the data necessary to detect and solve these cases was largely available within the organization under investigation and could have been used to prevent the red flag from erupting into a full-blown scandal.

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Thursday
Mar292018

Two Wall Street compliance officers charged for ignoring red flags

The SEC alleged Wednesday that two former anti-money laundering compliance officers for a New York broker dealer aided and abetted their firm's AML violations.

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Monday
Aug282017

Bethany Hipp: How can compliance officers protect themselves from harm?

Recent enforcement actions suggest that regulators, both in the United States and the UK, are targeting compliance officers.  

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Wednesday
Jul132016

What does ISO 37001 say about due diligence?

ISO 37001-- a new standard for anti-bribery management systems -- slated to be published in late 2016, is expected to be more detailed and internationally recognized than similar guidance published to date.

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Monday
Apr112016

The Unaoil story (remember that one?) has already raised the bar for reacting to red flags

The Huffington Post/Fairfax Media’s report of bribery at Unaoil is another cautionary tale on how entire industries can find themselves under investigation for use of the same intermediary.

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Thursday
Mar312016

SFO: How should companies handle attorney-client privilege during investigations?

Alun Milford, SFO General Counsel (image courtesy fo the SFO)In a speech this week to compliance professionals at the European Compliance and Ethics Institute in Prague, the general counsel of the UK Serious Fraud Office talked about attorney-client privilege in connection with SFO corruption investigations.

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Monday
Nov302015

Barclays fined $108 million for kowtowing to rich PEPs

The UK Financial Conduct Authority fined Barclays Bank £72 million ($108 million) Thursday for rushing to serve rich politically exposed persons and keeping their deal secret.

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Tuesday
Nov032015

Overreacting to risk can ruin a compliance program

In-house counsel, compliance officers and the external counsel who support them are trained to be risk averse when it comes to anti-corruption and other types of compliance, and with good reason.

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Tuesday
May192015

Inside view: What do corrupt organizations look like?

The concept of corporate culture -- generally defined as "the way we do things around here" -- isn't a rigid paper process. It's hard to measure, which explains why corporate culture has been largely neglected by regulators and the anti-corruption-consulting industry.

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Tuesday
Jan132015

Je Suis Charlie: Compliance protects us all

The global demonstrations that gathered under the banner “Je Suis Charlie” had special meaning for us at the University of Miami as we offered the second iteration of our undergraduate Compliance Boot Camp.

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Tuesday
Jul152014

Walmart in Delaware: A tale of red flags ignored

At oral argument Thursday in the Delaware Supreme Court, where Walmart is appealing a lower court order to produce internal FCPA investigation files to shareholders, one remarkable exchange indicated that the idea of revising the Caremark standards, which I talked about in my prior post, was squarely on the minds of the justices.

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