FCPAméricas Blog
How CCOs Can Use the OECD Foreign Bribery Report
1.09.2015
Last month, the OECD published its first Foreign Bribery Report, measuring transnational corruption based on data from the 427 foreign bribery cases that have been investigated, prosecuted, and concluded since the entry into force of the OECD Anti-Bribery Convention in 1999. In a panel discussion on December 10th, 2014, hosted by the OECD, International Bar Association, and The World Bank, James Tillen, the Vice Chair of Miller & Chevalier’s International Department, discussed how Chief Compliance Officers (CCOs) can pu... Read more
Top FCPA Enforcement Trends To Expect in 2015
12.30.2014
The FCPA enforcement picture in 2015 will be dynamic. Recent blockbuster actions like the DOJ’s record-breaking $772 million settlement with Alstom and aggressive statements of late by FCPA enforcement officials foreshadow a 2015 in which the U.S. Government’s approach to transnational bribery will be anything but relaxed. In particular, companies and businesspeople should watch for the following trends:
More Actions. Enforcement officials make clear that companies should expect continued prioritization of FCPA cases. Senior Deputy Chief of the DOJ Criminal Division’s Fraud Section James Koukios said in October 2014, “It’s fair to assume that the penalty amounts are not goi... Read more
Book-Ending FCPA Compliance: The Importance of Risk Assessments and Monitoring
12.23.2014
Over the last four years, at ACI’s winter International Conference on the FCPA, enforcement officials have repeatedly placed special emphasis on two specific compliance areas: risk assessments and monitoring.
To be sure, these officials have discussed many of the essential elements of an effective anti-corruption compliance program, including tone from the top, internal reporting mechanisms, trainings, and third party due diligence (FCPAméricas has posted summaries from 2011, 2012, 2013... Read more
