General
When assessing your third-party risks, it is important to start with one important division -- a company's supply chain and on the flip side, a company's distribution chain. Sourcing materials and supply chain links present a set of risks. Conversely, a company's distribution chain,
Podcasts
How do you manage risk when the vulnerabilities are outside your organization aren’t in your hands? In this episode of Corruption, Crime, and Compliance, we delve into the world of third-party risk management with our guest, Natalie Druckman, from Certa. As we discuss the regulatory landscape in EMEA
General
We have seen an explosion in the attention paid to legal, compliance and operational risks companies face in supply chain operations. Depending on the industry, companies have to address a wide-swath of supply chain risks, identify those issues that need to be mitigated and promote transparency and management of
General
It may seem like a Herculean task -- but it can be done. I regularly opine that mitigating sanctions risks for your third-party population is an easier task than doing so for your anti-corruption risks. One big reason -- geography is an important limiter on sanctions risks. The ability to
General
Remarks given by Commerce Secretary Gina Raimondo and Undersecretary Alan Estevez during the 2024 Policy Update Conference sponsored by the U.S. Department of Commerce's Bureau of Industry and Security (“BIS”) emphasized the need for organizations to enhance their due diligence efforts to prevent the diversion of restricted
General
When it comes to FCPA enforcement and expectations, DOJ has moved the goalposts. Some would argue that DOJ has been consistent all along. The truth, like most issues, lies somewhere between the extremes. With lots of fanfare, DOJ implemented a new Corporate Enforcement Program to udnerscore its intent to examine
Events
December 6, 2023 12 Noon EST SIGN UP HERE The Department of Justice recently announced revisions to its Merger and Acquisition Corporate Enforcement Policy to encourage voluntary self-disclosures. DOJ Deputy Attorney General Monaco outlined the new Mergers & Acquisitions Safe Harbor Policy. Under this new Policy, companies that promptly
General
The Albemarle FCPA enforcement action was announced at a good time. This year has been a slow year for DOJ's FCPA enforcement program, although there are several months before the end of the year. The SEC, on the other hand, has been steady this year -- the Albemarle and
General
The SEC has been racking up several FCPA enforcement actions. DOJ appears to be declining many of these cases. The division of enforcement appeared to follow a pattern – on larger cases with more pervasive violations, DOJ and the SEC would each bring an enforcement action; while on relatively “smaller” cases,
General
After a long-running investigation, Koninklijke Philips (“Philips), a Dutch company, resolved FCPA violations in China by agreeing to pay the SEC $62 million. Philips is a global manufacturer of medical equipment. Philips agreed to pay $15 million in civil penalties and more than $47 million in disgorgement and prejudgment
General
Even with the current focus on sanctions compliance, many companies have done little to assess and enhance their existing sanctions compliance program. Instead, a number of companies have stitched together a basic sanctions compliance program that centers on a screening tool and little beyond that. Such a limited program provides
General
Companies have to demand a new focus from their CEOs, senior executives and legal compliance team in response to the new DOJ and regulatory initiatives. These steps are not just suggestions nor items that can be prioritized based on resources. Instead, these are essential and basic requirements that will inevitably