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Entries in Adequate Procedures (7)


FCPA defendants need an ‘adequate procedures’ defense, too

The Department of Justice recently updated and published its guidelines for evaluating corporate compliance programs in the FCPA context. The Guidelines are remarkably thorough, but the text is aimed principally at assisting prosecutors with charging decisions, setting sanction amounts, and crafting subsequent compliance obligations -- rather than at the corporate entities that are expected to phase in those compliance programs.

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Malaysia imposes corporate and personal liability for organizational bribery

In the wake of Malaysia’s 14th General Elections in May this year, an important piece of legislation seems to have slipped under the radar.

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Frédéric St-Martin: Legal incentives for whistleblowing in the private sector

As mentioned in a prior post, ex post protective measures for whistleblowers are insufficient on their own. Considering the economic benefits brought by effective reporting mechanisms, private firms need to adopt proactive measures that will avoid whistleblower victimization and lead to meaningful organizational change.

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Heads up: The UK Government has an anti-corruption plan

Image courtesy of HM GovernmentOn December 18, 2014 the UK Government issued its long awaited “UK Anti-Corruption Plan.” The plan sets out over sixty action points for the Government and its partners, organized around four key themes of “Pursue,” “Prevent,” “Protect” and “Prepare." 

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What's changed under the UK Bribery Act? Due diligence in mergers and acquisitions

Two years after the Bribery Act 2010 came into force, the hysteria surrounding the Act has abated. There are fewer media pundits pronouncing the end of UK plc as we know it and there are fewer newly invented “legal experts” opining on an area they knew little or nothing about but which they saw as a potential earner to fill the gaping hole left by declining litigation and commercial transactions.

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U.K. anti-corruption enforcement threatened by budget cuts

The Government has proceeded to cut the budget of the Serious Fraud Office (SFO), the main enforcement agency, from £50 million in 2008/9 to below £30 million for 2013/14.

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New Proposal For FCPA 'Adequate Procedures' Defense

Jon Jordan propose his own version of an adequate procedures defense to the FCPA.

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