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Corruption, Crime & Compliance Blog

Articles: 1-10 of 96

DOJ “Tweaks” FCPA Corporate Enforcement Policy

USA - March 26 2019 The Justice Department is wedded to its FCPA Corporate Enforcement Policy (excuse me for the use of “wedded,” we recently celebrated our son’s…

FCPA Enforcement Ramping Up Against Private Equity and Hedge Funds (Part III)

USA - October 11 2016 The Och-Ziff settlement has now set the stage for the Justice Department and the SEC to focus its enforcement eye on the private equity and hedge…

Och-Ziff Failures in Due Diligence and Transaction Compliance (Part II)

Democratic Republic of Congo, USA - October 10 2016 The Och-Ziff enforcement action is replete with examples of failures in due diligence and transaction monitoring compliance. Och-Ziff’s bribery…

DOJ and SEC Deliver Body Blow to Private Equity and Hedge Funds: Och-Ziff Settles FCPA Violations for $412 Million (Part I)

USA - October 9 2016 The Justice Department and the Securities Exchange Commission delivered a powerful FCPA enforcement message to private equity and hedge funds…

The Recalibration of Compliance: What is the Definition of Success?

USA - October 5 2016 Some of this is the result of a political backlash. Chief compliance officers are the darlings in the corporate governance world, and there are…

GSK Settles SEC FCPA Case for $20 Million

USA - October 4 2016 The SEC finished with the last nail in GSK China's coffin by announcing a $20 FCPA million settlement for GSK's violations in China. The Justice…

Double Play, Double Declinations: DOJ Pushes FCPA Pilot Program Benefits

USA - October 4 2016 DOJ’s FCPA Pilot Program was panned when it was announced in April 2016. Critics contended that the incentive for voluntary disclosure of FCPA…

5 Key Takeaways from AB InBev SEC FCPA Settlement

India, USA - October 2 2016 The Justice Department and the SEC have been busy over the last 2 weeks in the FCPA arena. For those who have raised doubts about DOJ and the SEC’s…

Dig a Little Deeper: The Importance of Beneficial Ownership

USA - September 29 2016 Companies interact with a large number of entities in the outside world - customers, third party intermediaries and vendors and suppliers to name the…

Match Made in Heaven: Compliance and Human Resources

USA - September 27 2016 The corporate compliance function is only as successful as its partnerships with key internal constituencies. Depending on the company and the…