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...

Earth Day
April 23 2009

“Today is Earth Day and it doesn’t take much imagination to follow the trail from a lot of environmental destruction back to bribery.
Indonesia is facing terrible deforestation.   Western multinationals, sensitive to the campaigns of...

Training:   When Americans are “International Consultants”
April 22 2009

“We asked in-house counsel and compliance officers to provide examples of issues that arose during in-person training that might not have been uncovered through any other form of training.  Most of the examples involved very specific questions about...

“If that is in your law, please fix it.”
April 18 2009

“Four of the nine commissioners from Thailand’s National Anti-Corruption Commission spent this week in Washington describing their anti-corruption efforts and learning more about the American model. I had the opportunity to meet with them informally...

Training the Ethical Audience
April 16 2009

“Employees who believe themselves to have a strong moral compass can be hostile to the suggestion that they need compliance training. Kate Atkinson of Miller & Chevalier describes this training dilemma and offers some suggested responses.
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Training:  A European Perspective
April 14 2009

“Last week’s posting on anti-bribery training challenges generated a lot of interest. To follow-up, this week we will post a series of short pieces on training tips and challenges. We invited Jean-Pierre Méan to provide a European perspective. ...

Training:  What Works?
April 9 2009

“Not long ago, at an anti-bribery conference in Chicago, the compliance officer for an American corporation told the crowd of fellow compliance officers, “You have to start out with the assumption that all marketing people are more or less criminals....

BAE:  “It’s all tosh”
April 6 2009

“At a pre-screening event at Berkeley this weekend, Frontline’s Lowell Bergman and Oriana Zill de Granados launched “Black Money”, their documentary about international bribery. Amongst those in the audience were Helen Garlick, formerly of the...

In Brazil:  Benevolence or Bribery?
April 3 2009

“During anti-bribery training for almost 200 people in Sao Paulo and Rio de Janeiro this week, some clear themes emerged. TRACE representatives Carolyn Lindsey and Paula Orlando report that many participants expressed concern about frequent requests...

State-owned, State-controlled and State-supported Entities
April 1 2009

“With high levels of privatization in some industries and government bail-outs in others, the always-difficult question of what constitutes a state-owned entity has become more complicated.
Carlos Ortiz of DLA Piper, TRACE’s partner firm in New...