Photo Credit: Wikimedia Creative Commons France has long been criticized for falling short on enforcement of its international obligations to fight corruption abroad, including the OECD Anti-Bribery Convention that mandated member states to criminalize bribery of foreign public officials in international business transactions. That changed with the introduction of Sapin II, a new law similar… Read More

Photo Credit: http://riadzany.blogspot.com/2013_08_01_archive.html Forty years ago, President Jimmy Carter signed into law a novel statute called the U.S. Foreign Corrupt Practices Act (FCPA). It was the first-ever such statute in the world to govern business conduct abroad and address corruption violations involving bribery of foreign government officials. While the enforcement was initially slow, over time the… Read More

Photo Credit: Peter Linke (via Flickr) There is an ongoing debate regarding ‘pay by results’ in the international aid community. The pay by results (PbR) model is one in which aid recipient governments only receive donor funds upon achieving an agreed upon outcome – number of schools built, children inoculated, etc. For example, if the… Read More

Photo Credit: Wikipedia via https://en.wikipedia.org/wiki/File:Flags_south_america.png What makes the Odebrecht case so special? In December 2016, Brazil’s biggest construction company Odebrecht and its petrochemical subsidiary Braskem agreed to pay at least $3.5 billion to Brazilian, US, and Swiss authorities in a multi-country Foreign Corrupt Practices Act (FCPA) settlement. Aside from this record-breaking settlement, the Odebrecht case… Read More

Photo Credit: Flickr November 6-12, 2016 is Corporate Compliance & Ethics Week. Now in its 12th year, Corporate Compliance & Ethics Week continues to shine a spotlight on the importance of ethics and compliance in every workplace. One year ago, Deputy Attorney General Sally Quillian Yates issued a memorandum entitled “Individual Accountability for Corporate Wrongdoing,”… Read More

Late last week, one of the world’s largest integrated telecommunications services operators, VimpelCom, agreed to pay a $835 million settlement to U.S. and Dutch authorities. The company is accused of paying $114 million to Uzbek president Islam Karimov’s relative, widely believed to be his daughter, Gulnara Karimova. The U.S. Department of Justice (DoJ) claims that… Read More

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