The U.K and the European Union (EU) are bracing for the likelihood of a “no-deal” Brexit.
What makes a high impact compliance program? Given the state of many corporate compliance programs, it’s a question we get a lot. Here at MCO, we look at more than just the checklist of activities or the features or even the hotline to report potential violations. Fundamentally, business has shifted from simple checklists to how behavior is being impacted.
The Department of Justice (DOJ) has provided updated guidance for prosecutors evaluating corporate compliance programs’ adherence to Foreign Corrupt Practices Act (FCPA). “Okay,” you might be saying to yourself. “I know that already, the DOJ’s new guidance is very helpful.”
The Association of Corporate Counsel (ACC) published an article in May focusing on the top ten things small corporate legal departments need to know about complying with the Foreign Corrupt Practices Act (FCPA). While all ten are good to review, three stand out as critical to making sure your FCPA compliance program is more than just a written policy.
Telefônica Brasil recently agreed to pay the U.S. Securities & Exchange Commission (SEC) more than $4 million to settle charges brought against the organization for allegedly violating the Foreign Corrupt Practices Act (FCPA).
