Every U.S. company conducting or seeking business abroad is subject to the Foreign Corrupt Practices Act (FCPA) and it's no secret that 3rd party issues still present the highest risk under the FCPA. In fact, some say that 90%+ of reported FCPA cases involve third-party intermediaries! Yet many Boards and Audit Committees seem unsure as … Continue reading Audit Committee Primer on 3rd Party Risk Management
Copyright 2018 - Jonathan T. Marks Lack of separation of the CHIEF COMPLIANCE OFFICER (CCO) and the GENERAL COUNSEL (GC) has been cited as a cause of numerous corporate mishaps or failures. In fact, separation is now the norm in Health Care organizations. In spite of numerous recommendations to separate the two functions, there is … Continue reading Chief Compliance Officer v. General Counsel – Should They Be Separate?
Several years ago, Tom Fox was kind enough to post the “FCPA Compliance Overview and Action Plan” that I cobbled together based on my experiences. Since that time I have received many calls and e-mails for more information, so I decided to post it for others to consider using in practice. My goal is to continuously … Continue reading Board of Directors Guide to FCPA Compliance