• FCPA Guidance to be Released by Department of Justice

    Guest Post by David Quinones, Executive Director, International Association for Asset Recovery While it was just a brief comment during a lengthy speech, United States Assistant Attorney General Lanny Breuer’s mention of impending guidance on the resurgent Foreign Corrupt Practices […]

  • Michael Volkov on Internal Investigations: Best Practices

    Guest Post by Michael Volkov In-House counsel and corporate compliance officers dodge bullets everyday as they stare down the barrels of aggressive prosecutors, regulators, civil litigants, whistleblowers, disgruntled employees and shareholders prodded by trial attorneys to file derivative suits at […]

  • Dodd-Frank Whistleblower Rule Adopted by SEC Discourages Internal Reporting

    The Dodd-Frank Wall Street Reform and Consumer Protection Act, enacted on July 21, 2010, established a whistleblower incentive program requiring the Securities and Exchange commission to provide monetary awards to whistleblowers who come forward with information about the violation of […]

  • FCPA Books and Records Violations: The Government Will Always Win.

    The Foreign Corrupt Practices Act (FCPA) is aimed at preventing bribery of foreign officials. One key part of the FCPA is the books and records provision, which includes the following from 15 U.S.C. § 78m: (2) Every issuer which has […]

  • Books and Records Control Person and FCPA Enforcement

    I’ve recently been looking more closely at the Foreign Corrupt Practices Act (FCPA) as I consider the types of services companies will need from independent forensic accountants. This is an area in which government enforcement is skyrocketing, and so there […]

  • Learn From the Costly FCPA Mistakes of Others

    A recent Compliance Week article, An Expensive Lesson on FCPA Compliance [subscription required], provides some valuable insights on the direction that our government is taking with enforcement. Foreign Corrupt Practices Act violations are a huge focus of the feds right […]

  • The Case for Independent Internal Investigations

    The United States Sentencing Guidelines (USSG) continue to make life tough for those in charge of corporate compliance and ethics. Corporate attorneys, both in-house and outside counsel, must ensure that companies are following protocols set for by the USSG. Rightfully, […]