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

“We asked Kate Atkinson of Miller & Chevalier for some practical suggestions for avoiding problems with customs officials.

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"This is a perennial issue in anti-corruption compliance -- getting lots...

Gifts and Hospitality in the Year of the Ox
February 9 2009

“As Lunar New Year celebrations came to a close last week, many in the compliance world were left wondering if they gave more offense than pleasure with their New Year gifts and whether they incurred more risk than benefit.
Today’s post is...

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...