If you have not noticed, please take a look at the top of my blog site and you will see that the Red Flag Group now powers my site. In the field of disclosures that means the Red Flag Group is now the sponsor of my blog and podcast. I am pleased to announce, in [...]
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The Justice Department finally released its long-awaited new FCPA enforcement plan. It took DOJ a little while to come up with this and in the end, like most initiatives, there is a mixed bag for global companies, FCPA practitioners, DOJ prosecutors and law enforcement.
Today’s posting analyzes the initiative on prosecution issues, and tomorrow’s post will review the compliance component of the new guidance.
DOJ’s new plan consists of three important elements:
- Expansion of the FCPA Unit by assignment of ten new prosecutors;
- Increased coordination with foreign law enforcement agencies; and
- Implementation of a pilot program to increase voluntary disclosures by incentivizing companies to disclose and cooperate to prosecute individual violators.
The first two elements of DOJ’s announcement is nothing Read more…
My thanks to the 232 people who answered my short survey. I wanted to know how many have shifted to basing their audit plan on risks to the enterprise (perhaps linked to their organization’s ERM program); how many remain with the traditional approach of addressing risks to individual processes, business units, or locations; and how […]
Today, I conclude my weeklong exploration of doing business in Cuba from the perspective of the Foreign Corrupt Practices Act (FCPA) with some final observations. One of the key themes throughout this week’s blog posts has been the inherent complexity of preparing for and then doing business in Cuba when such opportunities become available. All [...]
The post Doing Business in Cuba Under the FCPA, Part V appeared first on Compliance Report.
The post Episode 246-Risk Assessments Under the FCPA appeared first on Compliance Report.
I continue my exploration of some of the issues around doing business in Cuba, from the Foreign Corrupt Practices Act (FCPA) perspective. Today I want to consider the types of ownership structures that are currently in place and the FCPA issues deriving therefrom. At this time there are three recognized forms of investment: (1) Joint [...]
The post Doing Business in Cuba Under the FCPA, Part IV appeared first on Compliance Report.