In the corporate compliance world, an internal investigation is often the moment of truth. Whether triggered by a whistleblower complaint, a regulatory inquiry, or a suspicious transaction, the investigation’s quality…
In the corporate compliance world, an internal investigation is often the moment of truth. Whether triggered by a whistleblower complaint, a regulatory inquiry, or a suspicious transaction, the investigation’s quality…
We continue our deep dive into the Asante Berko FCPA conviction. Today we consider the jury’s verdict. The jury returned three guilty verdicts. That is the decisive legal result, but…
In compliance, risk management is more than a checklist. It is the ongoing discipline of identifying threats, assessing their potential impact, and implementing measures to mitigate or neutralize them before…
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…
