Tags » Foreign Corrupt Practices Act

Why Do People Care So Much About the Proposed FCPA Compliance Defense?

A while back I posted a commentary on the proposal to add a so-called “compliance defense” to liability under the Foreign Corrupt Practices Act (FCPA). My basic take was that despite all the attention and controversy surrounding this proposal, in fact it would not make very much difference in practice. 1,507 more words


Miss Marple Short Stories and SEC Enforcement of the FCPA, Part V - Final Thoughts

I conclude my week of exploration of Agatha Christie’s Miss Marple short stories and the Securities and Exchange Commission’s (SEC) enforcement of the Foreign Corrupt Practices Act (FCPA) by reviewing some of the new things I’ve learnt during this week of research. 1,675 more words


Ingots of Gold & SEC FCPA Enforcement - Communication - Part IV

Today I want to use the Christie’s story Ingots of Gold as an introduction to some of the regular communications that the Securities and Exchange Commission (SEC) representatives frequently provide in public forums, regarding their views on Foreign Corrupt Practices Act (FCPA) enforcement and, more importantly for the compliance practitioner, FCPA compliance. 1,548 more words


The Blue Geranium - SEC Enforcement of the FCPA – Part III

In Christie’s The Blue Geranium a difficult and cantankerous semi-invalid wife is looked after by a succession of nurses. They changed regularly, unable to cope with their patient, with one exception Nurse Copling who somehow managed the tantrums and complaints better than others of her calling. 1,526 more words


Responsibility, Accountability and the FCPA Institute in Houston

What is accountability in your compliance program? How does it relate to responsibility for a company to prevent, detect and remediate any issues that might arise under a Foreign Corrupt Practices (FCPA) compliance program? 1,152 more words


Why Och-Ziff Clients Disregard Lawsuits

Chidem Kurdas

This is a dramatic example of how the interests of financial company stakeholders can 469 more words


Taking the Rolls Out for a Spin? Maybe You Should Avoid Brazil

Just as the GlaxoSmithKline PLC (GSK) case in China heralded a new day in international anti-corruption enforcement, the Petrobras case may be equally important going forward. 1,251 more words