Blog

Blog

Friend or Foe?  Selecting a Compliance Monitor
February 5 2009

“Buried in the news of Siemens' staggering settlement with US authorities, was an important "first":  the DoJ permitted Siemens to retain a non-American compliance monitor.   Given the discomfort with continued oversight by teams of US lawyers, this...

And now a few predictions from the United Kingdom...
February 4 2009

“At an anti-corruption summit held in snow-dusted London yesterday, a spokesman for the UK government braved the weather to deliver predictions for that country's anti-bribery trends for 2009.
Fortunately, he did not predict 'more of the same'. ...

Simple Strategies
February 3 2009

“It has become increasingly common for companies to prohibit facilitating payments on the grounds that they’re expensive, risky and corrosive of good governance more generally. This leaves employees with clear guidance at the policy level, but few...

Enforcement Predictions from the SEC
February 2 2009

“The ABA’s Anti-Corruption Committee held a Brown Bag Lunch on January 30th:  FCPA Enforcement Under the Obama Administration? A Look Ahead…
 
Although understandably reluctant to predict how the Obama Administration might impact enforcement...

Bribery’s Broken Windows
January 30 2009

“Imagine the following scenario: A Greek diplomat arrives in Washington and finds that his furniture and household items have been held up in customs at the Port of Baltimore. The Greek official dispatches his driver with $300 and tells him to spread...

FCPA Enforcement:  Top Ten Trends for 2009
January 28 2009

“At an anti-corruption conference in Frankfurt yesterday, there were two candid and forthcoming enforcement panels.  The US Department of Justice and SEC, together with prosecutors from Germany, the United Kingdom, Jersey and Switzerland, opened with...

Entrepreneurial Government Officials
January 27 2009

“While companies like Halliburton announce (prematurely) half-billion dollar settlements of wild-eyed bribery schemes, most companies continue to wrestle with very real, but far more mundane compliance challenges.
Today’s challenge refers not to...

Driving Bribery Off the Books in Russia
January 23 2009

“Richard Dean, of Baker & McKenzie, TRACE's partner firm in Russia, Azerbaijan and Kazakhstan warns that a little learning can be a dangerous thing in the field of compliance. Many of us have occasionally had the uncomfortable feeling that our...

Questioning Competitors' Conduct
January 22 2009

“Many companies are reluctant to act when they suspect bribery by a competitor because the allegation is so serious and, short of actually observing the pay-off, the company can't be certain of the facts. Often, the most a company will have is a...

Compliance "Wish List" for the Obama Administration
January 21 2009

“The reviewing stands are still being dismantled along Pennsylvania Avenue and the new President and First Lady have just finished up their rounds of inaugural balls, but one could hear in the sharp cadence of his inaugural speech that Barack Obama...