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National Defense November 2015 Bradel & Ralph |
Justice Memo Calls for Absolute Cooperation The Foreign Corrupt Practices Act is a statute aimed at eliminating corporate bribery of foreign government officials. A defense contractor doing work overseas must be familiar with its tenets. |
National Defense September 2005 Shaheen & Geren |
Penalties Get Tougher For FCPA Violations The government is cracking down on bribes by government contractors to foreign officials. |
National Defense July 2010 Anderson & Goodwin |
Anti-Bribery Case in China a Wake-Up Call The recent Rio Tinto case in China is a powerful reminder why a vigilant and robust Foreign Corrupt Practices Act of 1977 (FCPA) corporate compliance program is important. |
Pharmaceutical Executive December 1, 2010 Chaturvedi & French |
US Anti-Corruption Regulation Risks Stepped-up enforcement of the Foreign Corrupt Practices Act requires enhanced global coordination of compliance |
National Defense November 2011 Piazza & Ayers |
Regulators Flex Foreign Corrupt Practices Act Enforcement Muscles Continuing a trend that started late in the last decade, the Securities and Exchange Commission this year continues to raise the bar on the enforcement of the Foreign Corrupt Practices Act of 1977. |
Pharmaceutical Executive June 1, 2007 Cook & Leiken |
Legal: Foreign Policy Drug companies doing business abroad face a special risk of running afoul of stepped-up enforcement of anticorruption laws. |
Pharmaceutical Executive May 1, 2006 Cook & Witten |
Legal: The Kickback Effect Pharma tends not to treat relationships with foreign doctors as cautiously as it does those with US physicians. But watch out: Misconduct on the part of your international employees could get kicked back onto your plate. |
National Defense September 2012 Richard L. Moorhouse |
Implementing Evolving Disclosure Rules Federal government oversight, scrutiny of contractors and enforcement actions are on the rise. |
National Defense February 2009 David H. Laufman |
Mandatory Disclosure Regime Raises Stakes for Contractors A new regulatory enforcement regime has now commenced that underscores the Department of Justice's aggressive approach to procurement fraud and dramatically increases the compliance and disclosure obligations of defense contractors. |
National Defense August 2010 Patrick & Renzulli |
Defense Contractors Increasingly Targeted in Corruption Investigations Companies and individuals are facing dramatically higher penalties and costs for failing to comply with anti-bribery laws around the world, and especially in the United States. |
National Defense September 2015 Kopp & Bhatia |
U.S. Cracking Down on Defense Industry Corruption Overseas The race for international sales during the past few years has been followed by a wave of government investigations into defense companies for both major and relatively minor violations of the Foreign Corrupt Practices Act. |
National Defense July 2009 Latour & Maki |
Companies Must Resist Temptations to Cut Corners The defense industry must counter any temptation to cut corners that could result in violations of the Foreign Corrupt Practices Act (FCPA). |
National Defense November 2010 Marinelli & Latour |
Vetting Partners: A Key Compliance Element Vetting vendors and other partners is a critical element of a comprehensive export compliance program. |
CFO September 1, 2008 Kate O'Sullivan |
Gunning for Global Graft The Department of Justice and the SEC turn up the heat on briberies of foreign officials. |
National Defense January 2006 Reeder & Hickey |
Make Commitment To Corporate Ethics The National Defense Industrial Association puts ethical conduct on par with shareholder profits and believes maintaining the highest ethical standards throughout the defense industry has never been more important to the country. |
CFO January 1, 2005 David M. Katz |
The Bribery Gap While foreign rivals may make payoffs routinely, U.S. firms face new pressure to root out abuses. |
National Defense February 2011 Pappalardo & Bombach |
Justice Department Beefs Up Foreign Corruption Act Enforcement Enforcement of the Foreign Corrupt Practices Act gained momentum in 2010. |
National Defense July 2007 Manik K. Rath |
Mergers, Acquisitions Call for Added Scrutiny When acquiring or merging with any government contractor, reviewing ethics policies, compliance programs, and all recent voluntary disclosures will provide a wealth of invaluable information. |
National Defense July 2014 Chris Nagel |
Whistleblowers Cash In On False Claims Act A startling trend in defense contracting is the recent rise in payments made by industry to government agencies and whistleblowers under the False Claims Act. |
Pharmaceutical Executive January 1, 2013 Ben Comer |
Compliance in the C-Suite Compliance officers have risen into pharmaceutical management's highest ranks, by choice in some organizations, and by government decree in others. Either way, their importance as a strategic partner can hardly be understated. |
National Defense January 2012 David Hickey |
Cutting Costs Does Not Require Cutting Compliance Lest anyone think the federal government will tolerate less contractor compliance, the current environment indicates that it is much more likely that the government will pursue allegations of non-compliance, fraud, waste and abuse with even greater vigor. |
OCC Bulletin December 14, 2005 |
Small Entity Compliance Guide This compliance guide summarizes the obligations of financial institutions to protect customer information and illustrates how certain provisions of the Security Guidelines apply to specific situations. |
National Defense December 2010 O'Neill et al. |
The Long Arm Of the U.K. Bribery Act For U.S. companies, particularly those active in foreign countries or engaged in high-profile markets such as the defense industry, maintaining ethical operations and avoiding corruption is essential. |
National Defense January 2015 Ryan Berry & Guy Filippelli |
Compliance Programs Need Data Analytics Without data analytics tools, companies remain dependent on human identification of risks and violations. Their compliance efforts often consist only of training employees to spot misconduct, and in setting aside financial reserves to fund expensive, after-the-fact investigations by outside counsel. |
National Defense June 2008 D'Agostino & Parker |
Self-Disclosure Rules Create Ambiguities It is unclear if a recently proposed disclosure regulation will become final, but the attention it has received from Congress suggests increased mandatory disclosure is likely to occur in some form. |
National Defense May 2013 Canni & Levy |
Agencies Becoming More Aggressive in Pursuit of Contractor Wrongdoing After years of congressional complaints, federal agencies are responding to concerns about how they handle contractor debarments and suspensions. New civilian debarment offices have emerged and are becoming active. |
CFO April 15, 2012 Sarah Johnson |
Coverage for Uncovered Secrets New insurance products will compensate companies for the costs of internal investigations. |
National Defense January 2016 Thomas B. McVey |
Executives: Be Wary of Export Regulations One of the important legal requirements facing defense contractors is compliance with International Traffic in Arms Regulations and export controls. |
CFO February 1, 2012 Sarah Johnson |
Don't Trust, Verify With antibribery actions on the rise, companies should monitor their business partners more closely than ever. |
National Defense February 2009 McGrath & Connolly |
Final Rules on Mandatory Disclosure Effective Dec. 12, 2008, government contractors will face what rule authors characterize as a "sea change" in how government enforcement authorities expect to govern in the future. |
Pharmaceutical Executive August 1, 2014 Severin Wirz |
Only Fools Rush In The importance of pre-acquisition due diligence. |
Pharmaceutical Executive December 1, 2010 William Looney |
Is Euroland Following the US Disclosure Lead? Cegedim Relationship Management survey documents whether European industry is ready for the challenge of new compliance and disclosure risks on promotional spending. |
National Defense March 2012 Jacob Pankowski |
Take Heed of Post-Employment Restrictions The new Defense Acquisition Regulation System clause requires offers on Defense Department contracts to represent that all covered ex-department officials expected to work on any resulting contract are in compliance with all post-employment restrictions. |
National Defense March 2010 Fennelly & Epstein |
Defense Contractors Must Effectively Monitor Consultants As corporate ethics and compliance programs are reviewed and strengthened to meet increasing competition and government requirements, companies may not recognize the risks posed by consultants and other agents. |
The Motley Fool December 7, 2004 Rich Smith |
InVision Sees End of Tunnel A Department of Justice settlement for violations of the U.S. Foreign Corrupt Practices Act (FCPA) clears the way for acquisition of the tiny bomb detector by GE. |
National Defense June 2015 Bruce J. Casino |
All Government Contractors Subject to New Human Trafficking Rule Effective March 2, a new federal government rule concerning human trafficking went into effect, directly impacting all 300,000 plus government contractors and many more subcontractors. |
CFO January 1, 2008 Kate O'Sullivan |
Foreign Intelligence CFOs need to be smart about overseas operations -- or risk paying a heavy price. |
National Defense October 2015 Berry & Hutchens |
Creating an Ethics Compliance Program Government agencies and mature prime contractors expect emerging contractors to reflect the same "culture of ethics and compliance" that large companies commit substantial resources to implementing. |
IndustryWeek March 16, 2011 |
Schooled By Scandals Manufacturers burned by foreign bribery scandals provide valuable lessons for companies expanding their global presence. |
The Motley Fool March 8, 2004 Rich Smith |
Titanic Troubles for Lockheed? Lockheed's acquisition target, Titan, may be in trouble with the Feds. |
National Defense May 2011 Dawn M. Lurie |
DHS Expands Monitoring of Federal Contractors This initiative includes a sharp focus on employer compliance along with higher fines for those hiring undocumented workers. |
National Defense January 2007 David Hickey |
Companies Must Set and Review Compliance Priorities As 2006 closed, the Department of Justice's criminal division announced the formal creation of a national task force "to promote the prevention, early detection and prosecution of procurement fraud." |
The Motley Fool April 7, 2004 Rich Smith |
Lucent Sings to the Feds The company discovers further instances of possible bribery by its employees, this time in China. |
BusinessWeek July 8, 2010 Dexter Roberts |
The Higher Costs of Bribery in China The U.S. is policing the activities of big multinationals in China more aggressively, with China's own prosecutors sometimes following suit. |
OCC Bulletin March 1, 2006 |
Bank Secrecy Act/Anti-Money Laundering OFAC-Economic Sanctions Enforcement Procedures for Banking Institutions |
National Defense March 2006 Thomas O. Miller |
Corporate Liability: Beware of Rogues And Ostriches A corporation can be liable for a criminal or Civil False Claims Act violation stemming from the conduct of "rogue employees," who are politely known as "adverse agents," and employees who are willfully blind or deliberately ignorant of ethical, legal and contractual requirements. |
National Defense December 2007 Shaheen & Reeves |
Export Laws: Avoid The Scarlett Letter Complex U.S. export control laws and regulations are here to stay. The federal government is serious about export control enforcement, and violators are being severely punished. |
Financial Planning May 1, 2012 Jennifer Woods Burke |
Gotcha! Audits Get Tougher This year, the SEC and FINRA launched a webinar for firms detailing their expectations and reaffirming that whether a firm is large or small, regulators expect the same level of diligence when it comes to audits. |
Investment Advisor August 2006 Thomas D. Giachett |
Expert's Corner: A Process, Not a Destination With the advent of SEC Rule 206(4) 7, which requires SEC-registered investment advisors to implement and maintain policies and procedures appropriate for their investment advisory business, it is more critical than ever for all RIAs to recognize that compliance is an ongoing process. |
The Motley Fool January 8, 2004 Rich Smith |
Oops, I(BM) Did it Again Once again IBM finds itself embattled in bribing controversy abroad. |