Thomson Reuters Accelus has recently published a special report (PDF/1.43MB/28 pages) on anti-bribery and corruption and the increased burden on senior management. It is particularly pertinent in light of the Bribery Act 2010 (“Act”) coming into force tomorrow. Among other things, it contains some useful discussion on: sector specific issues and guidance; whether foreign issuers with a London … Continue Reading
Our sister blog here are Squire Sanders & Dempsey, Employment Law Worldview, recently published a tremendously informative and entertaining article on the corruption scandal currently surrounding FIFA. It is not so often that the world of sports and entertainment graces the Anticorruption Blog, but this one, “UK Bribery Act – a whole new ball game?”, … Continue Reading
The UK’s Bribery Act, scheduled to come into force on July 1, 2011, will have the most significant impact on the oil and gas industry, according to research by Ernst & Young. Ernst & Young’s findings are based on an analysis of bribery prosecutions under the U.S. Foreign Corrupt Practices Act (FCPA) over the last … Continue Reading
In July 2009, the Serious Fraud Office (SFO) issued a document entitled “Approach of the Serious Fraud Office Dealing with Overseas Corruption,” which encourages companies to approach the SFO to self report corruption in exchange for receiving a US-style plea bargain settlement, thus providing the company with certainty of outcome. However, in his white paper, … Continue Reading
Whilst we await the coming into force of The Bribery Act 2010 (“Act”) with baited breath, in the meantime, it is interesting to see the attempts to change the scope of the Act. There has also been no shortage of various interest groups calling for a delay in the Act’s implementation to allow them to … Continue Reading
In a recent post we analyzed the comments of Charles Duross, Deputy Chief, Fraud Section, Criminal Division, DOJ, at the ABA White Collar Crime annual conference. Today, we will summarize the comments of Duross’ fellow panelists — Robert Tarun, Mark Mendelsohn and Raphael Monty — all three of whom are in private practice. Tarun stated: … Continue Reading
With these words Charles Duross, Deputy Chief, Fraud Section, Criminal Division, Department of Justice – the country’s lead criminal prosecutor of FCPA – so began his comments at the recent American Bar Association White Collar Crime annual conference in San Diego, California. Duross characterized 2010 as “transformative” for the following reasons: Fraud Section Changes. Duross … Continue Reading
The UK government will push forward with the implementation of the UK Bribery Act after the OECD threatened to blacklist British companies if the new law is not enacted soon.… Continue Reading
And news has finally arrived: Richard Alderman of the Serious Fraud Office (SFO) confirmed today that the implementation of the Bribery Act will be delayed for a second time. The delay is tied to the finalization of the publication of the Adequate Procedures guidance by the Ministry of Justice (MOJ). One has to wonder how … Continue Reading
The Institute of Chartered Accountants of Scotland (ICAS) is on bended knees, urging the UK government to delay the implementation of the UK Bribery Act to July 2011 (instead of April 2011), stating that realistically small and medium sized businesses need more time to reorganize their internal policies and procedures to comply with the Act. … Continue Reading
The UK’s Bribery Act is slated to take effect in April…mere weeks away (10 by my reckoning). Draft guidelines have been prepared and are being circulated (after all, inquiring minds are eager to know about ‘adequate procedures’). The Act will put the UK — one of the world’s least corrupt countries — at the forefront of global … Continue Reading
Russia’s hosting a great party–everyone’s invited. Who will be able to survive the hangover from Russia’s samogon (moonshine)? U.S.-based Panalpina, Inc. and its parent Panalpina World Transport (Holding) Ltd., a Swiss freight forwarding company with 10 offices across Russia, were charged with FCPA violations that occurred in Russia. The charges were for both conspiring to … Continue Reading