General
The Justice Department announced the indictment in New York of Cary Yan, a Chinese entrepreneur, and Gina Zhou, his assistant, on FCPA and money laundering charges relating to a scheme to secure control of an atoll owned by the Republic of the Marshall Islands (RMI). Yan and Zhou paid bribes
Podcasts
In following the Justice Department and the Securities Exchange Commission FCPA enforcement actions, I am always reminded of the popular phrase — “reading the tea leaves.” (or “tasseography,” a fortune-telling method based on tea leave patterns in tea sediments). Despite a slow initial year in 2021, the Biden Administration’s
General
The broad and pervasive scope of Glencore's bribery conduct is obvious. The scope of its misconduct reflects Glencore's fatal culture and commitment to profits at any and all cost. Glencore's board and senior executive team forgot the basic equation -- ethical companies are more profitable
General
We have heard it over and over, again and again – third-parties pose significant risks of bribery for all global businesses. Almost every FCPA enforcement action includes some form of third-party misconduct. The current picture from the Stanford FCPA Resource confirms the story. A cottage industry of automated platforms,
General
In a surprising (but fully warranted) twist, the Justice Department returned an indictment against a former employee of Telefonaktiebolaget LM Ericsson (“Ericsson”), a global telecommunications company, for his role in paying approximately $2.1 million in bribes to high-level government officials in the Republic of Djibouti. Afework “Affe” Bereket,
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Chief compliance officers are always hungry for benchmarking data, for comparisons and insights around how their respective compliance programs stack up against other companies, especially in the same industry. Compliance professionals, as a general rule, are collaborative and willing to share information with each other. CCOs are an optimistic lot