The Investigation Protocol
January 23, 2024
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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
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
We continue our exploration of the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. Today we go full geek in a look at the fine
One cannot really say enough about risk assessments in the context of anti-corruption programs. This is because every corporate compliance program should be based on
This week we are taking a deep dive into the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. In it, SAP agreed to pay the
If there is one truism from the practice of law that translates to the practice of compliance, it is that you are only limited by