Yesterday in Part One of our series on the Asante Berko FCPA trial and conviction, we examined the prosecution’s mosaic. Today in Part 2, we ask the defense question that…
Yesterday in Part One of our series on the Asante Berko FCPA trial and conviction, we examined the prosecution’s mosaic. Today in Part 2, we ask the defense question that…
In the modern compliance landscape, third-party due diligence is not optional but essential. Regulators from the DOJ to the SFO have made it clear: if your business partner is involved…
A bribery case does not always arrive with a signed receipt. In the trial of former Goldman Sachs banker Asante Berko, prosecutors presented something different: a mosaic of evidence. They…
In the realm of corporate compliance, institutional justice and fairness are not mere aspirational slogans; they are operational imperatives. These principles govern how decisions are made, how investigations are conducted,…
Today, let’s take a journey to one of Star Trek: The Original Series’ most intense psychological dramas: “Whom Gods Destroy.” On its surface, this episode is a tale of madness, manipulation,…
Today, let’s set our phasers to “analyze” and travel back to one of Star Trek: The Original Series’ most underrated diplomatic dramas: “Elaan of Troyius.” This episode is not just a…
From Reinspection Fees to Executive Signatures: Final Lessons from Scoular The Scoular Company FCPA enforcement action began with a deceptively simple fact pattern. Customs brokers allegedly paid Mexican officials approximately…
Today, we set a course for one of Star Trek: The Original Series’ most underrated yet profound episodes: “The Empath.” As compliance professionals, we know that the heart of any…
The Scoular Company Deferred Prosecution Agreement (DPA) ends where every effective compliance program should begin: accountability. The agreement does not leave anti-corruption compliance solely with the Chief Compliance Officer, legal…
Today, we’re setting our sensors on one of Star Trek: The Original Series’ most thought-provoking episodes—“Wink of an Eye.” While this story may not feature the grand courtrooms or battlefields…