International Anti-Corruption Regulatory Trends And How To Prepare For Increased Foreign Enforcement
|
|
- Victor Nash
- 7 years ago
- Views:
Transcription
1 International Anti-Corruption Regulatory Trends And How To Prepare For Increased Foreign Enforcement Ariana N. Sarabia Gary R. Chadick Partners at McKenna Long & Aldridge LLP Contact Information: Ariana Gary mckennalong.com
2 Overview There has been a global increase in enforcement against corrupt business activities. More foreign governments are passing anti-corrupt legislation. Foreign regulators have begun to enforce their own existing domestic anti-corruption laws, sometimes in coordination with American investigations. Global watchdogs are highlighting certain high-risk industries and geographic locations. Here in the U.S., FCPA settlement amounts increased in Chinese cases top the list for ongoing FCPA investigations. Despite progress, enforcement is still poor in some surprising countries. 2
3 More Foreign Governments Are Passing Anti-Corruption Legislation UKRAINE Ukraine has a new anti-corruption law. New anti-corruption bureau is expected to be different from prior ineffective agencies. BRAZIL Brazil s anti-corruption bill Passed in the House of Representatives. Brazil has an extraordinary number of anti-bribery enforcement authorities. 3
4 Foreign Regulators Have Begun to Enforce Their Own Existing Domestic Anti-Corruption Laws, Sometimes In Coordination With American Investigations Despite the lack of significant regulatory reform in Asia, many regulators are stepping up enforcement efforts, perhaps signaling the public s intolerance with the degree of corruption. HONG KONG In Hong Kong, the Independent Commission Against Corruption (ICAC) is increasing investigations under the Prevention of Bribery Ordinance (POBO), which is broader in scope than the FCPA. The Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), effective 2012, is finally being enforced. U.S. and Hong Kong are working together (e.g., recent extradition of an executive charged with commercial bribery from the U.S. to Hong Kong to face trial). CHINA The Chinese Communist Party launched a high-profile anti-corruption campaign against public officials and private businesses. China is focusing on certain high risk sectors in accordance with the joint judicial interpretation by the Supreme People s Court and the Supreme People s Protectorate regarding aggravating circumstances pertaining to bribery of supervisory officials in key industries, including: pharmaceuticals medical devices food products energy 4
5 Global Watchdogs Are Highlighting Certain High-Risk Industries and Geographic Locations According to the December 2014 Foreign Bribery Report of the Organization for Economic Cooperation and Development ( OECD ), two-thirds of foreign bribery cases occurred in these four sectors: extractive/mining (19%), construction (15%) transportation and storage (15%) information and communication (10%) 5
6 Here In The U.S., FCPA Settlement Amounts Increased In 2014 In 2014, ten companies paid $1.56 billion to resolve FCPA cases. In 2013, twelve companies paid $731.1 million to resolve FCPA cases In 2012, twelve companies settled FCPA enforcement actions by paying a total of $259.4 million In 2011, 15 companies paid $508.6 million In 2010, 23 companies paid $1.8 billion In 2009, 11 companies paid $644 million In 2008, 11 companies paid $890 million In 4 of 6 corporate FCPA enforcement actions where an analysis was possible, the DOJ agreed to a criminal fine below the minimum range suggested by the sentencing guidelines. In these 4 actions, the average was approximately 29% below the minimum guidelines range and the distribution range was 9% below the minimum guidelines range (Avon) to 53% below the minimum guidelines range (Alcoa). In 2 corporate FCPA enforcement actions in 2014 (Alstom and Marubeni), the company paid a criminal fine within the guidelines range. 6
7 Chinese Cases Top The List For Ongoing FCPS Investigations There are currently over one hundred ongoing FCPA investigations. The alleged FCPA violations pertain to corruption in the following countries: China 40 investigations Brazil investigations Russia -- 9 investigations Libya -- 7 investigations India -- 7 investigations Poland 4 investigations Mexico 4 investigations Angola 4 investigations Saudi Arabia 4 investigations South Africa 4 investigations Italy 4 investigations Argentina 3 investigations Germany 3 investigations Kenya 3 investigations Romania 3 investigations Uzbekistan 3 investigations See january.html#sthash.cjl9ipr4.dpuf 7
8 Countries with Surprisingly Poor Enforcement France: In December 2014, the OECD highlighted France's lack of initiative in cases involving French enterprises and bribery. Turkey: Turkey s parliament voted to acquit four former ministers who faced graft charges. Transparency International slammed the vote. 8
9 How To Prepare For Increased Foreign Enforcement Perform A Compliance Risk Assessment of Your Company s Compliance With All Applicable Anti-Corruption Laws Identify High, Medium, And Low Risk Foreign Third Parties Understand Where Your Company Does Business Internationally And Foreign Third Parties Critical To International Business Understand The Anti-Corruption Laws And Enforcement Trends In Those Countries 9
10 Elements Of An Effective Anti-Corruption Compliance Program Develop An Effective Anti-Corruption Compliance Program Assign Senior Leadership Perform the Compliance Risk Assessment Have Explicit Company Policies, Processes And Internal Controls Provide Communication And Training (Employees And Third Parties) Conduct Due Diligence Of Foreign Third Parties, Implement A Review And Pre- Contract Approval Process And Include Anti-Corruption Terms In The Contract Monitor And Audit Third Party and Employee Adherence to Contract and Internal Processes Provide An Ethics Help/Hotline Take Disciplinary and Corrective Actions When Necessary Conduct Effectiveness Review Of The Program 10
11 Elements Of An Effective Risk Based Third Party Due Diligence Program Develop An Effective Risk Based Due Diligence Program Use A Questionnaire To Obtain Business, Ownership, Financial and Other Information From The Third Party Obtain Financial, Business License Registration Or Other Due Diligence Information From Commercial Vendors Trace International, Dun And Bradstreet, Kreller, etc. Perform Phone Or Face To Face Interview and Training Call Or Visit The U.S. Embassy Check Business References (Other U.S. Companies Preferred) Obtain An In-Country Lawyer Legal Opinion Check Denied Party List Through Commercial Vendors Such As Management Dynamics Or Thomson Reuters World Check Conduct Internet Searches For Ethical Or Dishonest Conduct 11
12 Elements of An Effective Contracting Process Develop An Effective Contracting Process An Internal Review And Approval Process Before Contracting (Assess the Integrity and Reputation Of The Third Party Based On The Due Diligence Materials) Pre-Contract Training On Anti-Corruption Laws And Company Policies And Processes A Contract Containing Anti-Corruption Covenants, Indemnification, Termination and Audit Rights Provisions Monitoring Activities And Adherence To The Contract Establish A Risk Based Contract Renewal Process 12
13 Other Elements Of An Effective Anti- Corruption Compliance Program Internal Controls Need To Be Put In Place Bank Accounts Clear Delegation Of Authority And Internal Controls For Creating Account And Withdrawing Cash Sales Rep/Consultant Invoices Need To Match Invoices To Compensation Terms In Their Contracts Books And Records Need To Be Accurate And Fairly Represent The Transactions Payments Need To Be Accurately Described In Your Company s Books And Records Facilitation Payments Need To Be Clearly Identified As Such Training And Periodic Audits Needed 13
14 How MLA Can Assist Clients Review Your Company s Existing Anti-Corruption Compliance Program And Make Enhancement Recommendations Strengthening Particular Elements Of Your Program Provide Country Analysis On Anti-Corruption Laws And Enforcement Trends Enhance Existing Policies, Processes Or Contract Terms Strengthen Your Risk Based Due Diligence Program Prepare Or Provide Anti-Corruption Training And Communication Materials Conduct Investigations Of Noncompliance Allegations Provide Recommendations And Draft Disclosures To The Government If Necessary 14
U.S. Foreign Corrupt Practices Act for Beginners
U.S. Foreign Corrupt Practices Act for Beginners This presentation, related materials and subsequent discussion are provided for educational purposes only. They do not constitute legal advice nor do they
More informationThe World Bank Reports on the Observance of Standards and Codes (ROSC) Overview of the ROSC Accounting and Auditing Program
The World Bank Reports on the Observance of Standards and Codes (ROSC) Overview of the ROSC Accounting and Auditing Program January 2004 OVERVIEW OF THE ROSC ACCOUNTING AND AUDITING PROGRAM CONTENTS I.
More informationIFA s 45 th Annual LEGAL SYMPOSIUM
LEGAL SYMPOSIUM The Foreign Corrupt Practices Act: What Every International Franchisor Must Know Moderator: Speakers: Eric L. Yaffe Gray Plant Mooty Washington, DC Mary C. Spearing Baker Botts L.L.P. Washington,
More informationWhat does it mean for Non-US Companies?
White Paper FCPA Enforcement What does it mean for Non-US Companies? September 2012 Last updated July 2014 Table of Contents FCPA enforcement: What does it mean for Non-US Companies? 3 International scope
More informationThe Latest Wave of Securities Enforcement Actions And What To Do About It
The Latest Wave of Securities Enforcement Actions And What To Do About It Robert Kent Chicago, IL 6 June 2012 Regulatory and Enforcement Environment Regulatory and Enforcement History Looking Back on a
More informationIntroduction to the U.S. Foreign Corrupt Practices Act
Introduction to the U.S. Foreign Corrupt Practices Act Pablo C. Ferrante June 2010 Partner 713-238-2662 pferrante@mayerbrown.com Mayer Brown is a global legal services organization comprising legal practices
More informationForeign Corrupt Practices Act (FCPA)/Bribery Act Integrity Due-Diligence & Investigations
Foreign Corrupt Practices Act (FCPA)/Bribery Act Integrity Due-Diligence & Investigations Clarity in a complex world www.mintzgroup.com How We Work: Because the reputations of companies and individuals
More informationWhat You Need to Know about the U.S. Foreign Corrupt Practices Act
What You Need to Know about the U.S. Foreign Corrupt Practices Act Angella Castille Faegre Baker Daniels LLP Presentation to Indiana University October 9, 2012 Overview Introduction Enforcement Trends
More informationANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
Issued: November 12, 2013 ANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY SCOPE This policy applies to all Magnetek, Inc. ( Magnetek ) employees, its subsidiaries and affiliates worldwide,
More informationForeign Corrupt Practices Act (FCPA)
Foreign Corrupt Practices Act (FCPA) FCPA Practice Team John J. Carney, Partner John J. Carney, a former Securities Fraud Chief, Assistant United States Attorney, U.S. Securities and Exchange Commission
More informationFCPA and International Compliance
FCPA and International Compliance Briefing to San Antonio Post, SAME C. Ernest Edgar IV General Counsel, Atkins North America 1 Agenda Understanding the FCPA The Nuts and Bolts of the FCPA Who Is Covered
More informationPROTIVITI FLASH REPORT
PROTIVITI FLASH REPORT Even Retailers and Consumer Products Manufacturers Must Manage Compliance with the U.S. Foreign Corrupt Practices Act and Other Anti-Bribery Laws May 3, 2012 Recent reports of alleged
More informationNavigating around business risks in Turkey. Cagdas Cataltas Control Risks
Navigating around business risks in Turkey Cagdas Cataltas Control Risks Outline Investing in Turkey Benefits Sectors Risks Understanding the country and your partners Case studies Investing in Turkey:
More informationUnderstanding the Foreign Corrupt Practices Act. A training program for Evergreen
Understanding the Foreign Corrupt Practices Act A training program for Evergreen 2012 Why this is Important to know The FCPA has had a significant impact on the way American firms do business since it
More informationG20 ANTI-CORRUPTION WORKING GROUP PROGRESS REPORT 2013
G20 ANTI-CORRUPTION WORKING GROUP PROGRESS REPORT 2013 September, 2013 G20 Anti-Corruption Working Group Progress Report 2013 ANTI-CORRUPTION WORKING GROUP PROGRESS Introduction 1. The renewal of the G20
More informationAnti-Corruption Enforcement and Compliance Update. Michael Volkov, Esq. Carlos Ortiz, Esq.
Anti-Corruption Enforcement and Compliance Update Michael Volkov, Esq. Carlos Ortiz, Esq. November 2012 Today s presenters and some notes... Mike Volkov Washington, D.C. Carlos Ortiz Washington, D.C. Welcome.
More informationPresident's Summary of Outcomes from the Experts Meeting on Corruption
President's Summary of Outcomes from the Experts Meeting on Corruption 12 October 2013 The Financial Action Task Force (FATF) and the G20 Anti-Corruption Working Group jointly convened an Experts Meeting
More informationThe Russian experience of the business community engaging into corruption prevention efforts
The Ministry of Economic Development of the Russian Federation The Russian experience of the business community engaging into corruption prevention efforts Elias Klochkov Deputy Director of the Department
More informationAn Update on FCPA Enforcement by the Department of Justice in the Life Sciences Industry
An Update on FCPA Enforcement by the Department of Justice in the Life Sciences Industry Harvard Health Policy Review and Rx Compliance Report December 13, 2010 John S. (Jay) Darden Partner Patton Boggs
More informationForeign Corrupt Practices Act and Anti- Corruption Laws Compliance, Investigations, and Defense
Foreign Corrupt Practices Act and Anti- Corruption Laws Compliance, Investigations, and Defense Starting in 2007, the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC)
More informationForeign business partners under the FCPA
Foreign business partners under the FCPA by Tom Fox 1 TITLE about the writer Thomas Fox has practiced law in Houston for 25 years. He is now assisting companies with FCPA compliance, risk management and
More informationCombating Tax Evasion through Transparency and Exchange of Information
Combating Tax Evasion through Transparency and Exchange of Information BSEC 23 November 2012 Simon Knott Global Forum Secretariat OECD What s at stake NO LEVEL PLAYING FIELD tax fraud and evasion lack
More informationDIGITAL RIVER, INC. FOREIGN CORRUPT PRACTICES ACT AND ANTI-BRIBERY POLICY. (Adopted by resolution of the Board of Directors on December 1, 2011)
DIGITAL RIVER, INC. FOREIGN CORRUPT PRACTICES ACT AND ANTI-BRIBERY POLICY (Adopted by resolution of the Board of Directors on December 1, 2011) Digital River, Inc. and our affiliates ( DR ) must comply
More informationCutting-Edge Third Party Risk Management
Cutting-Edge Third Party Risk Management SCCE Utilities & Energy Compliance & Ethics Conference Flora A. Francis Compliance Counsel Flow & Process Technologies GE Oil & Gas Houston, Texas February 25,
More informationClient Update Fourth Anti-Money Laundering Directive Comes Into Force
1 Client Update Fourth Anti-Money Laundering Directive Comes Into Force OVERVIEW LONDON Karolos Seeger kseeger@debevoise.com Matthew Howard Getz mgetz@debevoise.com Alex Parker aparker@debevoise.com Ceri
More informationThe Long Arm of the U.S. Foreign Corrupt Practices Act: Complying with the FCPA in the Vietnamese Landscape
The Long Arm of the U.S. Foreign Corrupt Practices Act: Complying with the FCPA in the Vietnamese Landscape Foreign Corrupt Practices Act: The Act What is the Act? Anti-Bribery Provisions Book and Record
More informationM&A in 2015: Successor Liability Under the FCPA. Norton Rose Fulbright US LLP Thursday, February 26, 2015
M&A in 2015: Successor Liability Under the FCPA Norton Rose Fulbright US LLP Thursday, February 26, 2015 Speaker Marsha Z. Gerber Partner Norton Rose Fulbright US LLP Marsha Gerber is a partner in the
More informationFraud-Related Compliance
Fraud-Related Compliance Areas of Compliance, Part 1: FCPA, SOX, PCAOB, Dodd-Frank 2015 Association of Certified Fraud Examiners, Inc. Foreign Corrupt Practices Act (FCPA) Enacted to prohibit corrupt payments
More informationThe ITAR and the FCPA: What You Disclose May Hurt You. October 7, 2014
The ITAR and the FCPA: What You Disclose May Hurt You October 7, 2014 Presenters Mark Srere Bryan Cave LLP Susan Kovarovics Bryan Cave LLP 2 Agenda Background on the FCPA Background on ITAR ITAR Part 129
More informationRegional Anti-Corruption Action Plan for Armenia, Azerbaijan, Georgia, the Kyrgyz Republic, the Russian Federation, Tajikistan and Ukraine.
Anti-Corruption Network for Transition Economies OECD Directorate for Financial, Fiscal and Enterprise Affairs 2, rue André Pascal F-75775 Paris Cedex 16 (France) phone: (+33-1) 45249106, fax: (+33-1)
More informationCompliance and Risk Assessment Sao Paulo June 13, 2016. Restricted Siemens AG 2016. All rights reserved.
Compliance and Risk Assessment Sao Paulo June 13, 2016 Restricted Siemens AG 2016. All rights reserved. siemens.com Siemens wrote 160 years of history filled with success & innovations 1847 1900 1949 2006
More informationChambers General Counsel Seminar
Chambers General Counsel Seminar FPCA: Current Challenges for In-House Counsel Gregory Kehoe Greenberg Traurig Michael Marinelli Greenberg Traurig Ernest Edgar Atkins North America Why is FCPA Important
More informationTHIRD PARTY. T i m L i e t z R e g i o n a l P r a c t i c e L e a d e r R i s k A d v i s o r y S e r v i c e s
MANAGING THIRD PARTY RISK T i m L i e t z R e g i o n a l P r a c t i c e L e a d e r R i s k A d v i s o r y S e r v i c e s Experis -- a different kind of talent company. Experis Tuesday, January 08,
More informationAnti-Corruption Compliance: Dealing with Regulators When a Company is Under Investigation
Anti-Corruption Compliance: Dealing with Regulators When a Company is Under Investigation Carrie Di Santo Aon Corporation Vice President and Global Chief Compliance Officer University of Illinois Combating
More informationMATTHEWS INTERNATIONAL CORPORATION
MATTHEWS INTERNATIONAL CORPORATION U.S. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY INTRODUCTION Principles Underlying the United States Foreign Corrupt Practices Act ( FCPA ). The FCPA s Anti-Bribery
More informationIntroduction to the Foreign Corrupt Practices Act (a training presentation for employees)
Introduction to the Foreign Corrupt Practices Act (a training presentation for employees) Introduction Thank you for participating in our Foreign Corrupt Practices Act (FCPA) training program. [Our Company]
More informationAnti-Money Laundering (AML) & Combating Financing Terrorism (CFT)
Anti-Money Laundering (AML) & Combating Financing Terrorism (CFT) Auditing the complex, unclear, and changing regulatory requirements and expectations Basics of Money Laundering Money laundering is the
More informationList of tables. I. World Trade Developments
List of tables I. World Trade Developments 1. Overview Table I.1 Growth in the volume of world merchandise exports and production, 2010-2014 39 Table I.2 Growth in the volume of world merchandise trade
More informationPEPs and the FCPA. Presented to 10 th Puerto Rican Symposium of Anti Money Laundering. February 28 March 1, 2013
PEPs and the FCPA Presented to 10 th Puerto Rican Symposium of Anti Money Laundering February 28 March 1, 2013 by Jay Perlman, Director Global Investigations & Compliance, Navigant Table of Contents I.
More informationAPEC General Elements of Effective Voluntary Corporate Compliance Programs
2014/CSOM/041 Agenda Item: 3 APEC General Elements of Effective Voluntary Corporate Compliance Programs Purpose: Consideration Submitted by: United States Concluding Senior Officials Meeting Beijing, China
More information360 o View of. Global Immigration
360 o View of Global Immigration In a fast moving global economy, remaining compliant with immigration laws, being informed and in control is more challenging than ever before. We are a globally linked
More informationThe Board s role in anti-corruption compliance
The Board s role in anti-corruption compliance Guardian and Guide Although much has been written about the increased regulatory enforcement risks facing companies, there has been a dearth of focus on how
More informationTHE US FOREIGN CORRUPT PRACTICES ACT ( FCPA ) COMPLIANCE POLICY AND GUIDELINES
THE US FOREIGN CORRUPT PRACTICES ACT ( FCPA ) COMPLIANCE POLICY AND GUIDELINES 1. INTRODUCTION 1.1 The purpose of this policy is to provide all employees, directors and officers of DRDGOLD Limited, its
More informationANTI-CORRUPTION COMPLIANCE SYSTEM CERTIFICATION
. CERTIFYING Basel Beijing Brussels Frankfurt ETHIC Intelligence Certification Committee Geneva London Istanbul Milan Paris Decision of Award and Registration ANTI-CORRUPTION COMPLIANCE SYSTEM CERTIFICATION
More informationForeign Corrupt Practices Act. The Rationale behind the Implementation of the FCPA
Surname 1 Name: Instructor: Course: Date: Foreign Corrupt Practices Act The Rationale behind the Implementation of the FCPA The foreign corrupt practices act, or FCPA for short, was enacted in 1997. During
More information9/20/2013. Compliance Due Diligence In Multi-National Transactions: Mergers & Acquisitions and Third Parties OVERVIEW TODAY S AGENDA
1 2 3 Compliance Due Diligence In Multi-National Transactions: Mergers & Acquisitions and Third Parties LOUIS PEROLD COMPLIANCE MANAGER, SASOL LTD. KRISTA MUSZAK SENIOR COMPLIANCE ANALYST, PAYCHEX, INC.
More informationGLOBAL DATA CENTER INVESTMENT 2013
2013 CENSUS REPORT: Global Data Center Investment 2013 GLOBAL DATA CENTER INVESTMENT 2013 2013 - Healthy Growth in Data Center Investment Globally Globally, the data center industry has continued to maintain
More informationBasel Committee on Banking Supervision
Basel Committee on Banking Supervision Implementation of Basel standards A report to G20 Leaders on implementation of the Basel III regulatory reforms November 2015 This publication is available on the
More informationDodd-Frank s Whistleblower Bounty Provisions: The First Wave of Tips Filed with the SEC and What Public Companies Should Do Now
Dodd-Frank s Whistleblower Bounty Provisions: The First Wave of Tips Filed with the SEC and What Public Companies Should Do Now Mike Delikat, ORRICK (mdelikat@orrick.com; 212.5065230) The Dodd-Frank Act
More informationThe Determinants of Global Factoring By Leora Klapper
The Determinants of Global Factoring By Leora Klapper Factoring services can be traced historically to Roman times. Closer to our own era, factors arose in England as early as the thirteenth century, as
More informationComplying with the FCPA - An Exploration of Ethical Issues Raised by Recent Cases: Lessons Learned from Recent Enforcement Actions
Complying with the FCPA - An Exploration of Ethical Issues Raised by Recent Cases: Lessons Learned from Recent Enforcement Actions Philip S. Brewster Brewster Law Firm LLC July 29, 2014 Schering Charitable
More informationPROTIVITI FLASH REPORT
PROTIVITI FLASH REPORT Is Department of Justice Dismissal of Morgan Stanley Case a Litmus Test for Corruption Risk Compliance? November 1, 2012 In April 2012, a former Morgan Stanley managing director
More informationGlobal EY FIDS Forensic Data Analytics Survey 2014
Global EY FIDS Forensic Data Analytics Survey 2014 Big risks require big data thinking The Eighth International Pharmaceutical Compliance Congress Dubai, United Arab Emirates Vincent Walden Partner, EY
More informationProgram. Faculty Directory
Department Telfer Going of Finance Global Canada Anti-Corruption Executive Leadership Program Program Faculty Directory Marvin Hough Telfer Executive in Residence Academic Director 30 Year Career at Export
More informationNews, Events & Publications
News, Events & Publications Kenneth Jull Presentations Panel Member, Canada-China Institute for Business & Development, Chinese Immigrants Doing Business in Canada Conference Program, Ryerson University,
More informationWhat Every Business Lawyer Should Know About Anti-Corruption
What Every Business Lawyer Should Know About Anti-Corruption Stephen King, MasterCard William Devaney, Baker & McKenzie, New York Marc Litt, Baker & McKenzie, New York Jonathan Peddie, Baker & McKenzie,
More informationSMIC Business Ethics Statement
SMIC Business Ethics Statement Business Ethics Program Declaration of Business Integrity Codes, Charters and Policies Business Ethics Compliance Procedures Dedicated Mailbox and Ethics Hotline 2 Declaration
More informationFraud-Related Compliance
Fraud-Related Compliance R. A. (Andy) Wilson, CFE, CPP VP Fraud & Compliance Sedgwick Claims Management Services, Inc. Introduction: Why Compliance Is Essential 2015 Association of Certified Fraud Examiners,
More informationAppendix 1: Full Country Rankings
Appendix 1: Full Country Rankings Below please find the complete rankings of all 75 markets considered in the analysis. Rankings are broken into overall rankings and subsector rankings. Overall Renewable
More informationHAS BRAZIL REALLY TAKEN OFF? BRAZIL LONG-RUN ECONOMIC GROWTH AND CONVERGENCE
HAS BRAZIL REALLY TAKEN OFF? BRAZIL LONG-RUN ECONOMIC GROWTH AND CONVERGENCE COUNTRY PROFILE: A COUNTRY IN TRANSFORMATION POLICY RECOMENDATIONS COUNTRY PROFILE Brazilian Equivalent Population in The World
More informationAsset and Income Disclosure for Judges: A Summary Overview and Checklist By Keith E. Henderson*
Asset and Income Disclosure for Judges: A Summary Overview and Checklist By Keith E. Henderson* Although judges often balk at the invasion of privacy that disclosure of their private finances entails,
More informationDeutsche Bank Global Transaction Banking. Securities Services. Overview
Deutsche Bank Global Transaction Banking Direct Securities Services Securities Services Overview Finding the right custodian with a long-term commitment to supporting its clients business is critical for
More informationFCPA 10 Hallmarks Self- Assessment
FCPA 10 Hallmarks Self- Assessment How exposed is your business to corruption risk? Take this assessment to find out if your systems are sufficiently robust to protect your business October 2014 Prepared
More informationHILLENBRAND, INC. AND SUBSIDIARIES. Global Anti-Corruption Policy Statement and Compliance Guide
HILLENBRAND, INC. AND SUBSIDIARIES Global Anti-Corruption Policy Statement and Compliance Guide Hillenbrand, Inc., including all of its subsidiaries (referred to collectively as the Company ), maintains
More informationFOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY Acuity Brands, Inc. is committed to maintaining the highest level of ethical and legal standards in the conduct of our business activities. The Company s
More informationMost countries will experience an increase in pharmaceutical spending per capita by 2018
6 Most countries will experience an increase in pharmaceutical spending per capita by 218 Pharmaceutical spending per capita, 213 versus 218 1,6 1,4 Pharmaceutical Spend per Capita 1,2 1, 8 6 4 2 US Japan
More informationHow To Know If You Can Get A Job At A Company
What Maritime Lawyers Need to Know about the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws? Presented by Evelyn M. Suarez & Jim Barratt 2015 Port Administration & Legal Issues Seminar
More informationSettlements Anti-Corruption Compliance Lessons from the Avon Settlements
Settlements Anti-Corruption Compliance Lessons from the Avon Settlements By Michelle J. Shapiro and Kiran Patel Dentons More than six years ago, in October 2008, Avon Products, Inc. (Avon Products) first
More informationBank of America Merrill Lynch Banking & Financial Services Conference
Bank of America Merrill Lynch Banking & Financial Services Conference Manuel Medina Mora Chairman of the Global Consumer Banking Council November 17, 2010 Consumer Banking in Citicorp Agenda Our Business
More informationOverview of the OECD work on transfer pricing
Overview of the OECD work on transfer pricing Written contribution to the Conference Alternative Methods of Taxation of Multinationals (13-14 June 2012, Helsinki, Finland) by Marlies de Ruiter, Head of
More informationFOREIGN CORRUPT PRACTICES ACT POLICY for PROJECT PROFESSIONALS GROUP PTY. LTD.
FOREIGN CORRUPT PRACTICES ACT POLICY for PROJECT PROFESSIONALS GROUP PTY. LTD. 1.0 Purpose and Scope of this Manual The purpose of this Policy is to ensure compliance by Project Professionals Group Pty.
More informationForeign Corrupt Practices Act Are Grease Payments Really Allowed? Recent Developments in FCPA Enforcement
Foreign Corrupt Practices Act Are Grease Payments Really Allowed? Recent Developments in FCPA Enforcement Presented by: S. Lane Tucker, Partner Stoel Rives LLP (907) 263-8411 sltucker@stoel.com November
More informationRegulation for Compliance with Anti-Corruption Acts
Regulation for Compliance with Anti-Corruption Acts 2014. 2. 24. Samsung Techwin Co., Ltd. Table of Contents Chapter 1 Article 1 Article 2 Article 3 General Rules Purpose Applicability Definition Chapter
More informationUdyen Jain & Associates Quality and expertise that you deserve. OCA, Organisation Conseil Audit Your vision, our expertise
Udyen Jain & Associates Quality and expertise that you deserve OCA, Organisation Conseil Audit Your vision, our expertise Mikaël Ouaniche Mikaël Ouaniche is a Chartered Accountant and Legal Auditor, Graduate
More informationAnti-Bribery Provisions of the Foreign Corrupt Practices Act: Application to Foreign Corporations and Individuals
Anti-Bribery Provisions of the Foreign Corrupt Practices Act: Application to Foreign Corporations and Individuals LeClairRyan Carlos F. Ortiz 973.491.3365 carlos.ortiz@leclairryan.com Valerie C. Charles
More informationManaging Third Party Risks in a Global Supply Chain
Managing Third Party Risks in a Global Supply Chain The Companies You Keep William Marshall, Hong Kong Ross Denton, London Jasper Helder, Amsterdam Baker & McKenzie Amsterdam N.V. is a member firm of Baker
More informationIn December 2009, the U.S. Department of Justice (DOJ) indicted two former executives
December 2009 Indictment of Haiti Teleco Executives Shows Continuing DOJ FCPA and Anti-corruption Focus in Latin and South America If you have any questions regarding the matters discussed in this memorandum,
More informationThe SEC's New Whistleblower Program: What It Means for Companies and How to Respond. July 22, 2011
The SEC's New Whistleblower Program: What It Means for Companies and How to Respond July 22, 2011 Agenda Introduction Presentation Questions and Answers (anonymous) Slides now available on front page of
More informationGlobal AML Resource Map Over 2000 AML professionals
www.pwc.co.uk Global AML Resource Map Over 2000 AML professionals January 2016 Global AML Resources: Europe France Italy Jersey / Guernsey 8 Ireland 1 Portugal 7 Luxembourg 5 United Kingdom 1 50 11 Spain
More informationDRAFT. Anti-Bribery and Anti-Corruption Policy. Introduction. Scope. 1. Definitions
DRAFT Change History: Anti-Bribery and Anti-Corruption Policy Control Risks Group Ltd Commercial in confidence Introduction This document defines Control Risks policy on the avoidance of bribery and corruption.
More informationForeign Corrupt Practices Act & Compliance Policy
Team Resources Management () INTEGRITY MANAGEMENT SYSTEM (IMS) Printed documents are considered uncontrolled. Controlled documents can be found on the Atlantica server. -2-POL-057 1 0 02-Dec-2013 1 of
More information30 Important Considerations for Effective FCPA Compliance
30 Important Considerations for Effective FCPA Compliance Effective design, good-faith implementation As enforcement of the Foreign Corrupt Practices Act (FCPA) has gone through the roof in recent years,
More informationGlobal Support to Develop Domestic Bond Markets in Emerging Market Economies and Developing Countries The Italian Experience.
Global Support to Develop Domestic Bond Markets in Emerging Market Economies and Developing Countries The Italian Experience. 22/23 September 2008 Frankfurt am Main Pierpaolo Battista Italian Ministry
More informationGlobal Compliance Audit
WHITE PAPER Global Compliance Audit Understanding the Critical Importance of FCPA and Export Management Compliance 333 Route 46 West Suite 200 Mountain Lakes, NJ 07046 1.866.611.7874 973.808.3366 fax 973.227.1873
More informationFCPA: Handling Increased Global Anti-Corruption Enforcement
FCPA: Handling Increased Global Anti-Corruption Enforcement Allison Hoffman, Incisive Media David Krakoff, Mayer Brown LLP Claudius Sokenu, Mayer Brown LLP David Wilkins, The Dow Chemical Company Mayer
More informationANTI BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
ANTI BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY THIS POLICY DOES NOT CREATE A CONTRACT OF EMPLOYMENT OR ALTER THE AT WILL NATURE OF ANY EMPLOYEE S EMPLOYMENT IN ANY WAY. 1. Statement of
More informationFRANCHISORS AND FRANCHISEES: UNDERSTANDING COMPLIANCE RISKS
FRANCHISORS AND FRANCHISEES: UNDERSTANDING COMPLIANCE RISKS Franchisors and Franchisees: Understanding Compliance Risks What do KFC, Liberty Tax Service, Fatburger, and Orkin have in common? In addition
More informationThe Fraud Section's Foreign Corrupt Practices Act Enforcement Plan and Guidancel
U.S. Department of Justice Criminal Division Fraud Section Washington, D.C. 20530 The Fraud Section's Foreign Corrupt Practices Act Enforcement Plan and Guidancel Bribery of foreign officials to gain or
More information41 T Korea, Rep. 52.3. 42 T Netherlands 51.4. 43 T Japan 51.1. 44 E Bulgaria 51.1. 45 T Argentina 50.8. 46 T Czech Republic 50.4. 47 T Greece 50.
Overall Results Climate Change Performance Index 2012 Table 1 Rank Country Score** Partial Score Tendency Trend Level Policy 1* Rank Country Score** Partial Score Tendency Trend Level Policy 21 - Egypt***
More informationRisks and threats of corruption and the legal profession
Risks and threats of corruption and the legal profession Survey 2010 www.anticorruptionstrategy.org Risks and threats of corruption and the legal profession: Survey 2010 Contents Introduction 6 A. About
More informationInternational Anti-bribery and Corruption Compliance
International Anti-bribery and Corruption Compliance Bribery and corruption take place to one degree or another in virtually every country in the world. The Foreign Corrupt Practices Act (FCPA) was enacted
More informationHOWARD UNIVERSITY POLICY
HOWARD UNIVERSITY POLICY Policy Number: 400-007 Policy Title: CONDUCTING GLOBAL BUSINESS IN COMPLIANCE WITH FOREIGN CORRUPT PRACTICES ACT Responsible Officer: General Counsel and Chief Compliance Officer
More informationCompliance with the Foreign Corrupt Practices Act
l Compliance with the Foreign Corrupt Practices Act Howard O. Weissman Vice President and Associate General Counsel-International Lockheed Martin Corporation Foreign Corrupt Practices Act U.S. statute
More informationGeneral Contract Clauses: Corporate Social Responsibility Representations and Warranties
General Contract Clauses: Corporate Social Responsibility Representations and Warranties Mark S. Ostrau and Ashley C. Walter, Fenwick & West LLP, with PLC Commercial These Standard Clauses provide general
More informationCorporate Code of Conduct
Corporate Code of Conduct Statement of Policy. It is the policy of Casa Mining Limited (the "Company") that all of its officers, directors, employees, contractors, consultants and agents representing the
More informationLAUREATE ANTI-CORRUPTION POLICY
LAUREATE ANTI-CORRUPTION POLICY Laureate Anti-Corruption Policy 1.0 PURPOSE AND BACKGROUND This Anti-Corruption Policy establishes basic standards and a framework for the prevention and detection of bribery
More informationRISK AND COMPLIANCE ISSUES ARISING FROM THIRD-PARTY BUSINESS RELATIONSHIPS
OCT-DEC 2013 REPRINT RC & risk compliance & RISK AND COMPLIANCE ISSUES ARISING FROM THIRD-PARTY BUSINESS RELATIONSHIPS REPRINTED FROM: RISK & COMPLIANCE MAGAZINE OCT-DEC 2013 ISSUE RC & risk c ompl & ia
More informationSecurities Litigation Alert The Foreign Corrupt Practices Act: The Next Corporate Scandal?
Securities Litigation Alert The Foreign Corrupt Practices Act: The Next Corporate Scandal? January 28, 2008 by christopher j. steskal As the stock option backdating cases wind down, what will be the next
More informationCC255 C O R P O R A T E. Altus FCPA Policy. Last revised: 12 October 2010
CC255 Altus FCPA Policy Last revised: 12 October 2010 C O R P O R A T E Foreign Corrupt Practices Act Policy Purpose The purpose of this Policy is to ensure compliance by Altus and its directors, officers,
More informationFCPA / Anti-Corruption Due Diligence What You Don't Know Can Hurt You
www.pwc.com FCPA / Anti-Corruption Due Diligence What You Don't Know Can Hurt You Agenda 1. Quick primer on FCPA 2. Current trends in Anti-Corruption due diligence 3. The need for Anti-Corruption due diligence
More information