Voluntary Disclosure in the UK?   More Clarity Promised Soon
May 28 2009

“Earlier this year, we tried to get the Serious Fraud Office to provide greater clarity on the benefits, if any, that would flow to companies in the UK for voluntarily disclosing anti-bribery payments.
This was the impenetrable response from the...

Anti-Bribery Enforcement in Estonia:  An Equivocal Process
May 27 2009

“Tallinn was abuzz about bribery this week. Perhaps that’s overstating things, but at meetings there yesterday, people were keen to discuss the prosecution and conviction of former Environment Minister, Villu Reiljan.
Just last week, Reiljan was...

Global Tips from Prague
May 21 2009

“TRACE works with partner law firms in 94 countries. These firms maintain local law materials, available on-line, and provide support for our workshops and other initiatives.
Every second year, experts from these partner firms gather to...

Cost-Effective Anti-Bribery Compliance Strategies:  Training Tip #1
May 19 2009

“A comprehensive approach to training far-flung employees can be daunting in terms of both time and expense. And yet, reaching these employees with a strong message and giving them a chance to ask questions relevant to their markets is critically...

Cost-Effective Compliance Strategies:  Rolling-out Responsibility
May 16 2009

“Assuming your company is sending the right message from the top, the next challenge is ensuring ownership beyond headquarters. How can anti-bribery compliance be made relevant to managers in the field? We have two suggestions.
One compelling...

Defining "Tone at the Top"
May 14 2009

“We'll post the second in our cost-effective compliance series tomorrow, --addressing how anti-bribery compliance can be made relevant to managers in the field. But first, I wanted to post the best description of “tone at the top” that I’ve heard to...

Cost-Effective Compliance Strategies:  Management Message
May 12 2009

“Compliance is expensive. The need for external lawyers, auditors, forensic accountants and in-house compliance teams is being questioned as budgets are cut in other areas. Department of Justice representatives have acknowledged that companies are...

When the Nigerians ask it of us.
May 6 2009

“The International Bar Association held its annual anti-corruption conference in Prague last week. Late on the final day of the conference, there was a panel devoted to facilitating payments, particularly with respect to corrupt customs officials....

"An Enforcement Rich Environment"
May 1 2009

“Former U.S. Attorney General John D. Ashcroft was the featured speaker at ACI’s FCPA and International Anti-Corruption for the Pharmaceutical and Medical Device Industries conference in New York yesterday.  Although Mr. Ashcroft’s presentation...

Due Diligence: Centralized or Local Review?
April 28 2009

“In the important -- if not very glamorous -- world of due diligence, there are still some unsettled issues.   Although we often hear debates about "whether, when and what", we rarely hear anyone ask where.   Nancy Etzwiler of 3M's Office of General...