MyComplianceOffice Blog

Conduct risk is a form of business risk that refers to potential misconduct of individuals associated with a firm, including employees, third-party vendors, customers or agents interacting with the firm. Read more on conduct risk, what regulators say about it and how to protect against it.

The month of June ended what has been one of the most active half-years in Foreign Corrupt Practices Act (FCPA) enforcement ever according to Thomas Fox. The attorney recently covered the subject in a JD Supra blog, citing many high-profile cases in 2019 along with the Department of Justice’s (DOJ’s) revised guidance on evaluating corporate compliance programs.  

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.” 

When it comes to enforcing the Foreign Corrupt Practices Act (FCPA), the U.S. Department of Justice (DOJ) is still trying to figure it out. That’s according to Mike Koehler, professor of Law at Southern Illinois University, who is an FCPA expert.  

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.