The DOJ FCPA Pilot Program: Best Practices, Benefits, and Risks of Cooperation In an ideal world, a company could simply disclose mistakes they have made that violated the FCPA, disgorge assets from the deal, and that would be the end of it. However, that’s not the case in today’s complex financial environment. It’s very…
How Companies Can Avoid FINRA and FCPA Violations If you watch the financial news, then you’ve seen a lot about Venezuelan bonds recently. That’s because more than a few firms suspended trading on these bonds, Morgan Stanley included. There was a particularly prevalent case in the media, that of ex-trader John Batista Bocchino, that…
Using Investigative Interviewing in The Private Sector for an FCPA Investigation Dealing with an FCPA violation is never easy. It’s a task that can be even more difficult when the person investigating isn’t sure how to even go about it. Investigative interviewing isn’t a skill that you’re born with. Instead, it’s one that you…
What the Development of FBI International Corruption Squads Means for Your Business The FBI is taking a hard line against businesses who engage in overseas corruption. That’s why we’re seeing the development of FBI International Corruption Squads. The squads are designed to investigate both sides of international corruption, from the entities that take the…
In January alone, trade between the US and the UK accounted for more than $7 billion. That’s only one month of business and it’s still more than most industries will see over the entire year. If you work in the financial industry, it’s highly likely—if not entirely necessary—that you’re going to do business with UK…
Money laundering was coined as a phrase back in the mafia’s heyday, when Dons funneled dirty money through laundromats to make it look legitimate. It has only continued to grow since the days of cash-only businesses. Now, it’s a global enterprise and one that might make up as much as 5% of the GDP. If…
Image Source | Flickr user ciocci It’s the call anyone in the financial industry hates to get. The phone rings and your compliance director tells you that you may have an FCPA violation. If there’s a chance that your internal procedures have failed, and you have an exposure, you’ll want to complete an internal investigation.…
Image Source | Flickr user asenat29 I once had a colleague who had just returned to the United States after working in Costa Rica for five years. He was an excellent employee except for one issue in particular. He was never on time for anything. If work started at 8:00, he showed up at 8:30.…
Image Source | Flickr user Quentin THEURET If you don’t know what you’re looking for, then the best investigation in the world isn’t going to help you. While we often tout the benefits of doing extreme vetting investigations, we don’t always think about the details of what makes these investigations so effective: the questions. President…
Image Source | Flickr user Moodycamera Photography Even though Trump’s administration has promised to deregulate many provisions of the FCPA, those provisions are still in place at this time, so FCPA compliance must remain a top priority for firms. However, as a wise business owner, you’re probably wondering how much is too much when it…