When I saw there was a press release from the UK’s Ministry of Justice, I was expecting an announcement of what it meant for a commercial organization to have “adequate procedures” to prevent bribery. That being the only affirmative defense under the Bribery Bill. It turns out that implementation of the Bribery Act will be [...]
Tag Archives: Mike Koehler
But Everyone Else is Doing it
In my hasty post on last week’s FCPA sting operation my focus was on the aggressive use of an undercover operation to catch violations of the Foreign Corrupt Practices Act. That was big news. It’s the first time that’s happened. The indictments did not disclose the companies involved. It’s now clear that this sting operation [...]
DOJ Nets 22 in FCPA Sting
“The largest single investigation and prosecution against individuals in the history of DOJ’s enforcement of the Foreign Corrupt Practices Act” The Department of Justice has gotten serious about the FCPA. “This ongoing investigation is the first large-scale use of undercover law enforcement techniques to uncover FCPA violations and the largest action ever undertaken by the [...]
Compliance Bits and Pieces for December 11
Here are some interesting stories from the past week. Tis the Season! Where are the gifts from vendors?? from Kathleen Edmond, Best Buy’s Chief Ethics Officer This time every year we send out reminders to our employees that we do not accept gifts from vendors. At the same time we send letters to our vendors [...]
Compliance Bits and Pieces
Here are some interesting compliance stories that have not made their into their own posts: Canada’s Commitment to Combating the Corruption of Foreign Public Officials: Watching Bill C-31 from the Wrageblog Bill C-31, An Act to amend the Criminal Code, the Corruption of Foreign Public Officials Act and the Identification of Criminals Act, was introduced [...]
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