The Brief
What changed, and what it costs you
Short, practical analysis of anti-bribery and corruption enforcement, written for general counsel and finance leads at companies that do not have a compliance department to read the rules for them.
EU Directive
Your FCPA programme will not satisfy Brussels
Four gaps that a US-built compliance programme does not close, and what closing them actually involves.
Third-party risk
The distributor is the exposure
Agents, distributors and customs brokers sit behind most bribery cases. Why, and the four controls that actually reduce the risk.
United Kingdom
100 to 130 hours, documented
What a failure-to-prevent-fraud risk assessment has to contain before it counts as reasonable procedures, and why your bribery assessment does not cover it.
Self-disclosure
A promised declination, and a narrower window
The DOJ now promises a declination to companies that come forward. The catch is timing, and the number of authorities who may hear first.