The FCPA, Iran Sanctions, and Compliance Convergence
My friends Howard Sklar and Tom Fox are fond of talking about “compliance convergence.” The idea is that, in an age where compliance expectations are created by a wide range of legal regimes –...
View ArticleMatteson Ellis Featured on This Week in FCPA
Be sure to watch the latest episode of This Week in FCPA (Episode #44). I join Howard Sklar and Tom Fox as a featured guest, alongside the Coordinator of Miller & Chevalier’s FCPA and...
View ArticleTen Rules for Effective Internal Investigation Interviews
Conducting interviews is a vital skill for internal FCPA investigators. After reviewing endless emails, technical memos and accounting ledgers, we almost always have to speak directly to someone in...
View ArticleThird Party Red Flags and Latin America
Looking back at FCPA enforcement actions in 2011 that involved Latin America, all but one included risk created “indirectly” by third parties. And that one, Tyson Foods, involved payments to spouses of...
View ArticleGoing Beyond the TI Index: New tools for assessing integrity risks
Enforcement officials and “best practice” descriptions stress that adequate anti-corruption compliance programs are based in sound corruption risk assessments. Howard Sklar recently provided an...
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