The role of the compliance professional and the compliance function in a corporation has steadily grown in stature and prestige over the years. When it
The role of the CCO has steadily grown in stature and prestige over the years. In the 2020 FCPA Resource Guide, 2nd edition, under the
There is nothing like an internal whistleblower report about a compliance violation, the finding of such an issue, or (even worse) a subpoena from the
The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a
After the internal report comes in and you have properly triaged the matter, you need to scope out and investigate it, promptly, thoroughly and with
Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of corruption
The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the life cycle management of third
As every compliance practitioner is well aware, even in 2023, third parties still present the highest risk under the FCPA. The 2023 ECCP devotes an
We conclude our series on the initial Foreign Corrupt Practices Act (FCPA) enforcement action. It involved the German software giant SAP. While the conduct which
After you complete your risk assessment, you must then translate it into a risk profile. If your estimate of where your bribery risk is greatest
