Blog

Blog

The Audit Rights Dilemma
March 18 2009

“Many companies routinely require audit rights in their agreements with intermediaries, -- and why not?  Audit rights strike most compliance professionals as a simple, low-cost process improvement that is easy to incorporate in contracts alongside...

Extortion Outflanks Business on Bribery’s Russian Front
March 11 2009

“TRACE released its BRIBEline report for Russia in Moscow earlier today.
 
It is unlikely to surprise business people active here, but bribe solicitation in Russia is frequently extortionate in nature (63% of all reports), involving requests...

Using Peer Pressure on Judicial Clerks
March 9 2009

“Compliance officers are often made uneasy by close personal relationships in opaque business settings.   They’ll routinely conduct extensive due diligence to reassure themselves that the risk of inappropriate influence is remote.   But what about...

Small 'c' corruption in Castro's Cuba
March 6 2009

“'Bribery' and 'corruption' are often used interchangeably, but the distinction is important in Cuba.  We have returned this evening from a week-long independent research trip to Havana and found some surprises there.

We spoke with...

Approaching the Sphinx:  The DOJ's Opinion Release Procedure
March 2 2009

“Most understand that bundles of cash paid to government officials in exchange for new business is a criminal act—or soon will be—in most countries. Between these blatant pay-offs and ending international marketing efforts altogether, lies a vast...

Fretting Over Freight Forwarders
February 27 2009

“Recent enforcement actions have reminded us that bribes paid with briefcases full of cash are not entirely obsolete. Nevertheless, most companies fret more over what their freight forwarders are getting up to than they do over that sort of epic...

Bribery “Hot Buttons”
February 23 2009

“Although the problem of commercial bribery can seem intractable, small, simple solutions – and a little dumb luck - can be very effective.   On a recent trip to Jakarta to host an anti-bribery workshop, we determined that we’d left it too late to...

Curling, Canada and Corruption
February 18 2009

“The excitement of returning from Scotland triumphant from the 100th anniversary match for the Strathcona Cup has begun to subside and my fellow Canadians are turning their attention back to their near-perfect record of not quite prosecuting...

FCPA Fines:  Where Does All the Money Go?
February 13 2009

“It’s difficult to imagine having to write checks for the sort of FCPA penalties we’ve seen recently:  $800 million for Siemens in December and, this week, $579 million for Halliburton and KBR.  But where does all that money go?  We asked Billy...

Don't Feed the Bears:  Avoiding Corrupt Customs Officials
February 11 2009

“BRIBEline is a web-based, multilingual tool for reporting bribe-demands by government officials.  TRACE has been collecting data on bribe-demands for about 18 months and, worldwide, customs officials don’t come out of it well....