Blog

Blog

“If that is in your law, please fix it.”
April 18 2009

“Four of the nine commissioners from Thailand’s National Anti-Corruption Commission spent this week in Washington describing their anti-corruption efforts and learning more about the American model. I had the opportunity to meet with them informally...

Training the Ethical Audience
April 16 2009

“Employees who believe themselves to have a strong moral compass can be hostile to the suggestion that they need compliance training. Kate Atkinson of Miller & Chevalier describes this training dilemma and offers some suggested responses.
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Training:  A European Perspective
April 14 2009

“Last week’s posting on anti-bribery training challenges generated a lot of interest. To follow-up, this week we will post a series of short pieces on training tips and challenges. We invited Jean-Pierre Méan to provide a European perspective. ...

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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