Blog

Blog

Training:  What Works?
April 9 2009

“Not long ago, at an anti-bribery conference in Chicago, the compliance officer for an American corporation told the crowd of fellow compliance officers, “You have to start out with the assumption that all marketing people are more or less criminals....

BAE:  “It’s all tosh”
April 6 2009

“At a pre-screening event at Berkeley this weekend, Frontline’s Lowell Bergman and Oriana Zill de Granados launched “Black Money”, their documentary about international bribery. Amongst those in the audience were Helen Garlick, formerly of the...

In Brazil:  Benevolence or Bribery?
April 3 2009

“During anti-bribery training for almost 200 people in Sao Paulo and Rio de Janeiro this week, some clear themes emerged. TRACE representatives Carolyn Lindsey and Paula Orlando report that many participants expressed concern about frequent requests...

State-owned, State-controlled and State-supported Entities
April 1 2009

“With high levels of privatization in some industries and government bail-outs in others, the always-difficult question of what constitutes a state-owned entity has become more complicated.
Carlos Ortiz of DLA Piper, TRACE’s partner firm in New...

Monitoring the Monitors
March 30 2009

“Imagine hiring a lawyer on the following terms: you may send as many associates as you like, at whatever hourly rate you choose, to as many of our domestic or foreign offices as you wish, for as long as you think appropriate. We’ll throw open our...

Toxic Transactions:  Bribery, Extortion and the High Price of Bad Business
March 26 2009

“Last night in New York, at an event graciously hosted from his Director’s chair by Martin Weinstein of Willkie Farr & Gallagher, TRACE launched its new anti-bribery training DVD. OK, it’s a training DVD, but everyone got into the “red carpet”...

FCPA Statute of Limitations—When are bygones really gone?
March 23 2009

“In light of the vast sums at stake in FCPA cases, many companies are asking when, if ever, past criminal acts are truly behind them. We asked our expert on all-things-DoJ, Billy Jacobson, and he responded with the DoJ perennial: It depends…
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The Audit Rights Dilemma
March 18 2009

“Many companies routinely require audit rights in their agreements with intermediaries, -- and why not?  Audit rights strike most compliance professionals as a simple, low-cost process improvement that is easy to incorporate in contracts alongside...

Using Peer Pressure on Judicial Clerks
March 9 2009

“Compliance officers are often made uneasy by close personal relationships in opaque business settings.   They’ll routinely conduct extensive due diligence to reassure themselves that the risk of inappropriate influence is remote.   But what about...

Small 'c' corruption in Castro's Cuba
March 6 2009

“'Bribery' and 'corruption' are often used interchangeably, but the distinction is important in Cuba.  We have returned this evening from a week-long independent research trip to Havana and found some surprises there.

We spoke with...